Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
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Royalty-related transfer pricing adjustment was deleted because audited records showed that research and development costs had already been recovered from associated enterprises with a markup of about 10%, making any further adjustment for an alleged unpaid intangible component unwarranted. The adjustment on management support services was also deleted because the assessee had benchmarked interlinked international transactions on an aggregated TNMM basis, and isolating one service for a different method was impermissible. The services, allocation mechanism, and supporting evidence were substantiated, so ALP at nil could not stand.
Royalty-related transfer pricing adjustment was deleted because audited records showed that research and development costs had already been recovered from associated enterprises with a markup of about 10%, making any further adjustment for an alleged unpaid intangible component unwarranted. The adjustment on management support services was also deleted because the assessee had benchmarked interlinked international transactions on an aggregated TNMM basis, and isolating one service for a different method was impermissible. The services, allocation mechanism, and supporting evidence were substantiated, so ALP at nil could not stand.
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