Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Income deemed to accrue or arise in India - As undisputed factual position that ESPN India has been remunerated at arm’s length and there are no adjustments suggested by the TPO in any of the assessment years under dispute. That being the case, no further attribution of profit can be made to the PE. - the distribution revenue received by the assessee is not taxable in India. - AT
Income deemed to accrue or arise in India - As undisputed factual position that ESPN India has been remunerated at arm’s length and there are no adjustments suggested by the TPO in any of the assessment years under dispute. That being the case, no further attribution of profit can be made to the PE. - the distribution revenue received by the assessee is not taxable in India. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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