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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Taxation of fees for technical services under Article 12 of the India-Singapore DTAA was addressed: the Tribunal applied the limited scope of Article 9 as a neutralisation rule for intra-group profit adjustments and rejected recharacterisation of the transaction. The assessee, a Singapore entity, was treated as a distinct legal person and its refurbishing services were held not taxable in India because Article 12(3) did not apply and Article 12(4)(a) was inapplicable since the services were not rendered in connection with payments described in paragraph 3. The Tribunal followed coordinate-bench precedent and deleted the addition for fabrication charges; appeal allowed.
Taxation of fees for technical services under Article 12 of the India-Singapore DTAA was addressed: the Tribunal applied the limited scope of Article 9 as a neutralisation rule for intra-group profit adjustments and rejected recharacterisation of the transaction. The assessee, a Singapore entity, was treated as a distinct legal person and its refurbishing services were held not taxable in India because Article 12(3) did not apply and Article 12(4)(a) was inapplicable since the services were not rendered in connection with payments described in paragraph 3. The Tribunal followed coordinate-bench precedent and deleted the addition for fabrication charges; appeal allowed.
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