Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
In transfer pricing for the marketing support services segment, the ITAT excluded EDCIL (India) Ltd. because its revenue arose from dealings with Government entities and it was not a proper uncontrolled comparable; it also excluded Just Dial Ltd. for diversified operations, ownership of intangibles and absence of segmental data. Info Edge (India) Ltd. was rejected for its different service profile, multiple web-based businesses and materially different FAR profile, while India Exposition Mart Ltd. was excluded because its exhibition and conference business had a markedly different business model and employee-cost structure. The Tribunal also found that the inclusion of Cyber Media Research & Services Ltd. required verification of conflicting financial statements and remanded that issue to the TPO for fresh consideration after hearing the assessee.
In transfer pricing for the marketing support services segment, the ITAT excluded EDCIL (India) Ltd. because its revenue arose from dealings with Government entities and it was not a proper uncontrolled comparable; it also excluded Just Dial Ltd. for diversified operations, ownership of intangibles and absence of segmental data. Info Edge (India) Ltd. was rejected for its different service profile, multiple web-based businesses and materially different FAR profile, while India Exposition Mart Ltd. was excluded because its exhibition and conference business had a markedly different business model and employee-cost structure. The Tribunal also found that the inclusion of Cyber Media Research & Services Ltd. required verification of conflicting financial statements and remanded that issue to the TPO for fresh consideration after hearing the assessee.
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