Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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ITAT allowed the assessee's appeal. It held that, for transfer pricing/section 80-IA(10)/80-IC purposes, the operating profit margin of the manufacturing unit located in a backward area of Himachal Pradesh must be computed excluding the benefit of excise duty and CST waivers, following the coordinate bench view that excise duty, sales tax and income tax are to be excluded from operating profits. Further, ITAT accepted the assessee's additional ground that excise duty exemption availed in the 10th year of operations constituted a capital receipt, relying on HC precedent treating such subsidies/exemptions, granted to promote industrial development and employment generation, as capital in nature while computing income under normal provisions.
ITAT allowed the assessee's appeal. It held that, for transfer pricing/section 80-IA(10)/80-IC purposes, the operating profit margin of the manufacturing unit located in a backward area of Himachal Pradesh must be computed excluding the benefit of excise duty and CST waivers, following the coordinate bench view that excise duty, sales tax and income tax are to be excluded from operating profits. Further, ITAT accepted the assessee's additional ground that excise duty exemption availed in the 10th year of operations constituted a capital receipt, relying on HC precedent treating such subsidies/exemptions, granted to promote industrial development and employment generation, as capital in nature while computing income under normal provisions.
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