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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On TP adjustment relating to computation of operating margins of selected comparables, the directions were held non-speaking because the panel addressed only bank charges and failed to adjudicate specific objections on items such as treasury expenses and interest on working capital loans, violating section 144C(5)/(8) and principles of natural justice; the matter was remanded for verification from audited financials, fresh consideration of all objections, and recomputation of arm's length margin. On foreign exchange loss and related brokerage/commission, the disallowance was sustained on merits, but the AO was directed to verify the correct quantum of loss claimed versus disallowed. On section 40(a)(ia), the AO was directed to verify the claim of lower TDS based on certificate and pass orders accordingly, allowing the ground for statistical purposes. - ITAT
On TP adjustment relating to computation of operating margins of selected comparables, the directions were held non-speaking because the panel addressed only bank charges and failed to adjudicate specific objections on items such as treasury expenses and interest on working capital loans, violating section 144C(5)/(8) and principles of natural justice; the matter was remanded for verification from audited financials, fresh consideration of all objections, and recomputation of arm's length margin. On foreign exchange loss and related brokerage/commission, the disallowance was sustained on merits, but the AO was directed to verify the correct quantum of loss claimed versus disallowed. On section 40(a)(ia), the AO was directed to verify the claim of lower TDS based on certificate and pass orders accordingly, allowing the ground for statistical purposes. - ITAT
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