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" ?
Computational errors in assessment were held rectifiable as apparent from record, since deduction under s.80-IA was disallowed twice to the extent already added via TP adjustment, Chapter VI-A deduction and MAT credit were wrongly computed, and income was taken from s.143(1) intimation instead of revised return; AO was directed to rectify and recompute demand/refund. In TP for management support services, functionally dissimilar/government and credit-rating comparables were excluded, resulting in assessee's margin being at arm's length; TP adjustment was deleted. Reimbursement of software costs from AEs at cost was held not to warrant mark-up; adjustment was deleted. SEB rate (not IEX) was adopted for captive power transfers; related TP adjustments were deleted. Absence of exempt income barred s.14A disallowance (including under MAT); disallowance was deleted. Enhanced s.80-IA claim and interest on receivables were remanded for verification. - ITAT
Computational errors in assessment were held rectifiable as apparent from record, since deduction under s.80-IA was disallowed twice to the extent already added via TP adjustment, Chapter VI-A deduction and MAT credit were wrongly computed, and income was taken from s.143(1) intimation instead of revised return; AO was directed to rectify and recompute demand/refund. In TP for management support services, functionally dissimilar/government and credit-rating comparables were excluded, resulting in assessee's margin being at arm's length; TP adjustment was deleted. Reimbursement of software costs from AEs at cost was held not to warrant mark-up; adjustment was deleted. SEB rate (not IEX) was adopted for captive power transfers; related TP adjustments were deleted. Absence of exempt income barred s.14A disallowance (including under MAT); disallowance was deleted. Enhanced s.80-IA claim and interest on receivables were remanded for verification. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
