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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Assessing Officer's reference to the Dispute Resolution Panel under section 144C was invalid where the Transfer Pricing Officer made no variation following a section 92CA request. The tribunal accepted the assessee's contention that an 'eligible assessee' status under section 144C is absent absent any proposed TPO variation, and therefore the AO wrongly invoked the DRP reference. Consequence: the assessment order was quashed and the assessee's appeal allowed.
Assessing Officer's reference to the Dispute Resolution Panel under section 144C was invalid where the Transfer Pricing Officer made no variation following a section 92CA request. The tribunal accepted the assessee's contention that an 'eligible assessee' status under section 144C is absent absent any proposed TPO variation, and therefore the AO wrongly invoked the DRP reference. Consequence: the assessment order was quashed and the assessee's appeal allowed.
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