Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s deletion of the transfer pricing adjustment under s. 92CA, confirming that the assessee's use of the CUP method for transactions with its AEs reflected arm's-length pricing. The Tribunal found the TPO/AO had not articulated specific reasons to reject the CUP comparables, had misconstrued facts by inaptly correlating man-month rates to the assessee's purchase transactions, and failed to adduce contrary material rebutting CIT(A)'s factual findings. CIT(A)'s acceptance of published SUNVIN price data and reliance on OECD guidance and precedent were endorsed. Grounds of appeal were dismissed for lack of merit.
The ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s deletion of the transfer pricing adjustment under s. 92CA, confirming that the assessee's use of the CUP method for transactions with its AEs reflected arm's-length pricing. The Tribunal found the TPO/AO had not articulated specific reasons to reject the CUP comparables, had misconstrued facts by inaptly correlating man-month rates to the assessee's purchase transactions, and failed to adduce contrary material rebutting CIT(A)'s factual findings. CIT(A)'s acceptance of published SUNVIN price data and reliance on OECD guidance and precedent were endorsed. Grounds of appeal were dismissed for lack of merit.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
