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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The dominant issue was whether payments for rework, segregation and repackaging attracted TDS under s.195 as "fees for technical services" under Expl. 2 to s.9(1)(vii). The tribunal held that the activities were routine and standardized, performed manually or mechanically on predetermined specifications, and did not involve specialized expertise or any new scientific process; the Revenue also did not dispute the nature of work. Consequently, the deletion of the disallowance was affirmed and the Revenue's appeal was dismissed. - ITAT
The dominant issue was whether payments for rework, segregation and repackaging attracted TDS under s.195 as "fees for technical services" under Expl. 2 to s.9(1)(vii). The tribunal held that the activities were routine and standardized, performed manually or mechanically on predetermined specifications, and did not involve specialized expertise or any new scientific process; the Revenue also did not dispute the nature of work. Consequently, the deletion of the disallowance was affirmed and the Revenue's appeal was dismissed. - ITAT
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