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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Transfer pricing adjustment for intra-group steam transfers was deleted after the appellate tribunal found the TPO/AO disregarded binding DRP directions and precedent; arm's length re determination was not sustained. The claim for enhanced deduction on steam transferred from an eligible captive unit to non eligible units was remitted to the Assessing Officer for verification and decision with an opportunity to be heard. Receipts from Renewable Energy Certificates were held to be capital receipts and excluded from book profits for MAT purposes. A suo motu disallowance under the rule for exempt income was deleted where no exempt income was earned.
Transfer pricing adjustment for intra-group steam transfers was deleted after the appellate tribunal found the TPO/AO disregarded binding DRP directions and precedent; arm's length re determination was not sustained. The claim for enhanced deduction on steam transferred from an eligible captive unit to non eligible units was remitted to the Assessing Officer for verification and decision with an opportunity to be heard. Receipts from Renewable Energy Certificates were held to be capital receipts and excluded from book profits for MAT purposes. A suo motu disallowance under the rule for exempt income was deleted where no exempt income was earned.
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