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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Under TNMM, comparables engaged in trading of medical equipment were retained where product identity was not required and the assessee had not challenged the TPO's search keywords. MDD Medical Systems Pvt. Ltd. and RMD Mediaids Ltd. were not excluded on the basis of alleged support-services activity, research and development, or product dissimilarity because their financials indicated product sales and similar trading functions. QMS Medical Allied Services Pvt. Ltd. was not treated as an extraordinary-event comparable merely because of fresh capital infusion, although the Assessing Officer was directed to verify the margin computation. Hoya Medical India Pvt. Ltd. and Hicks Thermometer (India) Pvt. Ltd. were remitted for verification of RPT compliance, filters, and functional profile, with exclusion or inclusion to follow the verified results.
Under TNMM, comparables engaged in trading of medical equipment were retained where product identity was not required and the assessee had not challenged the TPO's search keywords. MDD Medical Systems Pvt. Ltd. and RMD Mediaids Ltd. were not excluded on the basis of alleged support-services activity, research and development, or product dissimilarity because their financials indicated product sales and similar trading functions. QMS Medical Allied Services Pvt. Ltd. was not treated as an extraordinary-event comparable merely because of fresh capital infusion, although the Assessing Officer was directed to verify the margin computation. Hoya Medical India Pvt. Ltd. and Hicks Thermometer (India) Pvt. Ltd. were remitted for verification of RPT compliance, filters, and functional profile, with exclusion or inclusion to follow the verified results.
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