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...
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ITAT dismissed Revenue's appeals, upholding taxation of the assessee's receipts under Section 44BB rather than as FTS under Section 9(1)(vii) r.w.s. 44DA, following judicial consistency with earlier years in the assessee's own case. On offshore sale of equipment, ITAT accepted the assessee's 2% profit attribution for Indian operations, relying on prior coordinate bench findings that the assessee's selected comparables satisfied FAR analysis and yielded a weighted average margin of 1.69%. Consequently, no further profit attribution was warranted and AO was directed to accept the 2% margin.
ITAT dismissed Revenue's appeals, upholding taxation of the assessee's receipts under Section 44BB rather than as FTS under Section 9(1)(vii) r.w.s. 44DA, following judicial consistency with earlier years in the assessee's own case. On offshore sale of equipment, ITAT accepted the assessee's 2% profit attribution for Indian operations, relying on prior coordinate bench findings that the assessee's selected comparables satisfied FAR analysis and yielded a weighted average margin of 1.69%. Consequently, no further profit attribution was warranted and AO was directed to accept the 2% margin.
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