Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
In transfer pricing comparability analysis for a manufacturing segment, the ITAT treated the Safe Harbour definitions of core and non-core auto components as a guiding aid for FAR analysis even though the assessee had not opted for Safe Harbour Rules. Because the assessee manufactured shock absorbers in the core auto component segment, only functionally similar comparables were acceptable. Helmet and accessory manufacturers, Eicher Motors, and Special Engineering Services were excluded for functional dissimilarity; Nifco was also excluded because its related party transactions exceeded 25%, despite otherwise being in the automotive component space.
In transfer pricing comparability analysis for a manufacturing segment, the ITAT treated the Safe Harbour definitions of core and non-core auto components as a guiding aid for FAR analysis even though the assessee had not opted for Safe Harbour Rules. Because the assessee manufactured shock absorbers in the core auto component segment, only functionally similar comparables were acceptable. Helmet and accessory manufacturers, Eicher Motors, and Special Engineering Services were excluded for functional dissimilarity; Nifco was also excluded because its related party transactions exceeded 25%, despite otherwise being in the automotive component space.
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