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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Receipts from providing in-flight entertainment content to an Indian airline were assessed as fees for technical services under section 9(1)(vii) and Article 13 of the India-UK DTAA. Applying Article 13(4)(c), the "make available" condition required the payer to receive technical knowledge, experience, skill, know-how, or processes enabling independent application. As the Revenue failed to establish any transfer of know-how or technical knowledge to the payer, the consideration for supplying content did not constitute FTS, rendering the corresponding addition unsustainable and warranting deletion. - ITAT
Receipts from providing in-flight entertainment content to an Indian airline were assessed as fees for technical services under section 9(1)(vii) and Article 13 of the India-UK DTAA. Applying Article 13(4)(c), the "make available" condition required the payer to receive technical knowledge, experience, skill, know-how, or processes enabling independent application. As the Revenue failed to establish any transfer of know-how or technical knowledge to the payer, the consideration for supplying content did not constitute FTS, rendering the corresponding addition unsustainable and warranting deletion. - ITAT
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