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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In transfer pricing proceedings concerning interest on rupee-denominated non-convertible debentures issued to an associated enterprise, the ITAT upheld 10% as the arm's length rate because the same instruments had already been examined in the first year and the TPO had accepted that rate using SBI PLR as the benchmark for rupee-denominated instruments. The Tribunal also noted that payment and redemption were in Indian currency, supporting the CIT(A)'s acceptance of the rate. Revenue's challenge to deletion of the transfer pricing adjustment was rejected. The Tribunal further corrected the interest quantum to be adopted for the year, directing use of Rs. 8,27,24,756 as the proper amount.
In transfer pricing proceedings concerning interest on rupee-denominated non-convertible debentures issued to an associated enterprise, the ITAT upheld 10% as the arm's length rate because the same instruments had already been examined in the first year and the TPO had accepted that rate using SBI PLR as the benchmark for rupee-denominated instruments. The Tribunal also noted that payment and redemption were in Indian currency, supporting the CIT(A)'s acceptance of the rate. Revenue's challenge to deletion of the transfer pricing adjustment was rejected. The Tribunal further corrected the interest quantum to be adopted for the year, directing use of Rs. 8,27,24,756 as the proper amount.
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