Just a moment...

Top
Help
×

By creating an account you can:

Logo TaxTMI
>
Call Us / Help / Feedback

Contact Us At :

E-mail: [email protected]

Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters0/2000
TMI Blog
Home / RSS

Order restores issues to AO; directs benchmarking under s.92CA, deletes duplicate s.143(1) addition, allows s.80G, fixes book profit for s.115JB

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....The ITAT set aside and restored multiple issues to the file of the AO. The DRP's LIBOR+350 bps rate is held prima facie appropriate, but the AO is directed to require the assessee to benchmark the outstanding receivable by reference to the currency of invoicing and to determine ALP of the international transaction under s.92CA, applying suitable mark-up or reduction for transaction-specific risk; the assessee may argue working-capital adjustments for software/ITeS segments. A double addition made at s.143(1) and again in the final order is to be deleted. The AO must use the disclosed book profit of Rs.118,10,19,785 for s.115JB computation. Donations qualify for deduction under s.80G; AO to allow.....