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...
Captive IT/software development service providers may exclude giant comparables where the comparables' turnover is more than ten times the assessee's, so Infosys, Wipro, LTI Mindtree and Cybage were directed to be excluded. Where the remaining companies appeared to have diversified product, agency or consultancy functions, their FAR comparability could not be finally decided on the existing record, and the matter was remanded to the AO/TPO for fresh benchmarking. Delayed trade receivables from an associated enterprise were treated as a separate international transaction; interest was sustained in principle, but only after allowing a standard credit period before computing delay. The appeal was partly allowed for statistical purposes.
Captive IT/software development service providers may exclude giant comparables where the comparables' turnover is more than ten times the assessee's, so Infosys, Wipro, LTI Mindtree and Cybage were directed to be excluded. Where the remaining companies appeared to have diversified product, agency or consultancy functions, their FAR comparability could not be finally decided on the existing record, and the matter was remanded to the AO/TPO for fresh benchmarking. Delayed trade receivables from an associated enterprise were treated as a separate international transaction; interest was sustained in principle, but only after allowing a standard credit period before computing delay. The appeal was partly allowed for statistical purposes.
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