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...
Statutory refund interest requires correction of short computation and compensation where admitted interest remains unpaid through administrative dela...
Transfer-pricing adjustments for the project business segment required fresh consideration in line with the Dispute Resolution Panel's directions, without adjudication of their merits. The ITAT restored this issue to the Transfer Pricing Officer for a lawful fresh determination after hearing the assessee. The arm's length price of intra-group services was also remanded because the Transfer Pricing Officer had accepted that price in a subsequent assessment year; the merits were not decided. The Transfer Pricing Officer must reconsider the issue after providing an opportunity of hearing. The appeals for the relevant assessment years were allowed for statistical purposes.
Transfer-pricing adjustments for the project business segment required fresh consideration in line with the Dispute Resolution Panel's directions, without adjudication of their merits. The ITAT restored this issue to the Transfer Pricing Officer for a lawful fresh determination after hearing the assessee. The arm's length price of intra-group services was also remanded because the Transfer Pricing Officer had accepted that price in a subsequent assessment year; the merits were not decided. The Transfer Pricing Officer must reconsider the issue after providing an opportunity of hearing. The appeals for the relevant assessment years were allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 1980 
