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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Applying a 25% related-party transaction filter, the Tribunal excluded Liquidhub Analytics Private Limited because its RPT level exceeded the prescribed threshold and it could not be treated as an uncontrolled comparable. It held that the search matrix is only a tool for identifying comparables, so rejection of the assessee's proposed comparables merely for absence from that matrix was unsustainable; the matter was remitted for fresh FAR analysis and filter-based examination. The Tribunal also required parity between cost and revenue in ESOP reimbursement under a cost-plus model, directed fresh working capital adjustment analysis, and upheld receivables adjustment in principle while requiring recomputation at LIBOR plus 200 basis points for delay beyond the agreed credit period.
Applying a 25% related-party transaction filter, the Tribunal excluded Liquidhub Analytics Private Limited because its RPT level exceeded the prescribed threshold and it could not be treated as an uncontrolled comparable. It held that the search matrix is only a tool for identifying comparables, so rejection of the assessee's proposed comparables merely for absence from that matrix was unsustainable; the matter was remitted for fresh FAR analysis and filter-based examination. The Tribunal also required parity between cost and revenue in ESOP reimbursement under a cost-plus model, directed fresh working capital adjustment analysis, and upheld receivables adjustment in principle while requiring recomputation at LIBOR plus 200 basis points for delay beyond the agreed credit period.
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