Associated Capsules Pvt. Ltd. v ACIT [2020] 121 taxmann.com 103 (Mumbai – Trib.) Facts The assessee is engaged in the business of manufacturing empty hard gelatine capsules. The assessee provided Corporate Guarantee of 2.4 million Euros (Equivalent to Rs. 15.19 crores) to its Croatian AE. The assessee did not make any adjustment on account of […]
RENT FOR PREMISES ON BEHEST OF AE – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]
COST OF TERMINATION OF PROPERTY PURCHASE AGREEMENT – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]
EXPENDITURE CAPITALISED – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]
IMPACT OF AUDITOR QUALIFICATION ON OPERATING MARGIN COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]
RELOCATION EXPENSES – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]
FIXED ASSET WRITTEN OFF – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]
EXPORT INCENTIVES AND SUBSIDIES – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]
DONATION – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”. Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]
WHETHER EXPENSES DISALLOWED BY AO CAN BE CLAIMED AS NON-OPERATING IN NATURE FOR OPERATING MARGIN COMPUTATION
Rule 10B of Income Tax Rules provides methodology for computation of ALP. Under TNMM, ‘net profit’ is used as benchmark for ALP computation. During the assessment, the AO may disallow expenditure incurred by the taxpayer on various grounds like they are personal in nature, they are bogus expenditure, etc. The disallowance of the AO would […]