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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A second final assessment order for the same assessment year was held impermissible because a final order had already been passed pursuant to DRP directions; the later order was quashed as a duplicate assessment. Transfer pricing issues on intra-group services and royalty benchmarking were not finally decided and were remitted to the TPO for fresh adjudication and computation in line with earlier-year directions. Support service expenditure was held allowable on consistency with prior years, and the disallowance was deleted. Amortization of telecom licence fee and the related interest claim were sent back for consequential action in accordance with law. Deduction under section 80G for CSR expenditure, refund of excess dividend distribution tax at treaty rate, and road tax and VAT on leased assets were all allowed.
A second final assessment order for the same assessment year was held impermissible because a final order had already been passed pursuant to DRP directions; the later order was quashed as a duplicate assessment. Transfer pricing issues on intra-group services and royalty benchmarking were not finally decided and were remitted to the TPO for fresh adjudication and computation in line with earlier-year directions. Support service expenditure was held allowable on consistency with prior years, and the disallowance was deleted. Amortization of telecom licence fee and the related interest claim were sent back for consequential action in accordance with law. Deduction under section 80G for CSR expenditure, refund of excess dividend distribution tax at treaty rate, and road tax and VAT on leased assets were all allowed.
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