Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Under Rule 10B, reasonably accurate adjustments may be made in TNMM where a difference materially distorts net profit margin; depreciation on in-house software was treated as requiring adjustment because it substantially affected the assessee's PLI and the benchmarking exercise, and recomputation was directed. The Tribunal also accepted an upper turnover filter for comparability, holding that companies with vastly higher turnover than the assessee were not meaningfully comparable and must be excluded. On functional dissimilarity, the Tribunal found the existing record insufficient for a final finding because relevant submissions had not been properly examined, and remitted the issue to the TPO for fresh consideration.
Under Rule 10B, reasonably accurate adjustments may be made in TNMM where a difference materially distorts net profit margin; depreciation on in-house software was treated as requiring adjustment because it substantially affected the assessee's PLI and the benchmarking exercise, and recomputation was directed. The Tribunal also accepted an upper turnover filter for comparability, holding that companies with vastly higher turnover than the assessee were not meaningfully comparable and must be excluded. On functional dissimilarity, the Tribunal found the existing record insufficient for a final finding because relevant submissions had not been properly examined, and remitted the issue to the TPO for fresh consideration.
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