Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Classification of service - Business Support services or not - The Appellate Tribunal, referring to precedent cases, concluded that GTPL's activity of arranging transportation did not qualify as business support service. They emphasized that GTPL solely organized transportation without providing loading/unloading or other logistics services. The tribunal found no evidence of a contract for the provision of business support service between GTPL and their buyers. Therefore, they dismissed the revenue's claim regarding the nature of the service provided by GTPL.
Classification of service - Business Support services or not - The Appellate Tribunal, referring to precedent cases, concluded that GTPL's activity of arranging transportation did not qualify as business support service. They emphasized that GTPL solely organized transportation without providing loading/unloading or other logistics services. The tribunal found no evidence of a contract for the provision of business support service between GTPL and their buyers. Therefore, they dismissed the revenue's claim regarding the nature of the service provided by GTPL.
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