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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Where TNMM had been accepted as the most appropriate method, the net margin was held to subsume the effect of notional interest on outstanding receivables, so no separate upward adjustment was warranted and the receivables adjustment was deleted. The arm's length rate on ECB interest was upheld at LIBOR plus 200 basis points, following the assessee's earlier years, so that adjustment was sustained. Leasehold charges were treated as proportionately amortisable over the lease term, and the disallowance of the year's claim was vacated. Royalty was held not to permit separate benchmarking once aggregated under TNMM, but the issue was remitted because the operating cost used for PLI computation did not reconcile with the books.
Where TNMM had been accepted as the most appropriate method, the net margin was held to subsume the effect of notional interest on outstanding receivables, so no separate upward adjustment was warranted and the receivables adjustment was deleted. The arm's length rate on ECB interest was upheld at LIBOR plus 200 basis points, following the assessee's earlier years, so that adjustment was sustained. Leasehold charges were treated as proportionately amortisable over the lease term, and the disallowance of the year's claim was vacated. Royalty was held not to permit separate benchmarking once aggregated under TNMM, but the issue was remitted because the operating cost used for PLI computation did not reconcile with the books.
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