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Transfer-pricing adjustment for operational-expense...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of the adjustment.
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Transfer-pricing adjustment for operational-expense reimbursements to foreign associated enterprises was deleted because the Other Method was applied without identifying an uncontrolled price or comparable transaction, and transfer pricing cannot test expenditure allowability or genuineness where no mark-up, inflated pricing, or non-business spending is established. Unutilised foreign tax credit relating to income taxed in earlier years cannot be claimed later as a business deduction: Rule 128 confines credit to the year corresponding income is offered or assessed in India. Payments to non-resident recruitment, legal and tariff-publication providers did not attract withholding absent proof of Indian taxability; tariff publication did not make available technical knowledge. The related disallowance was deleted.
Transfer-pricing adjustment for operational-expense reimbursements to foreign associated enterprises was deleted because the Other Method was applied without identifying an uncontrolled price or comparable transaction, and transfer pricing cannot test expenditure allowability or genuineness where no mark-up, inflated pricing, or non-business spending is established. Unutilised foreign tax credit relating to income taxed in earlier years cannot be claimed later as a business deduction: Rule 128 confines credit to the year corresponding income is offered or assessed in India. Payments to non-resident recruitment, legal and tariff-publication providers did not attract withholding absent proof of Indian taxability; tariff publication did not make available technical knowledge. The related disallowance was deleted.
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