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The Appellate Tribunal addressed various Transfer Pricing (TP) issues. It directed the AO/TPO to consider only operating profit/cost for TP adjustment in IT enabled Services transactions. For interest on trade receivables, it mandated using market determined rates. Regarding TDS u/s 195, payments to a Thailand entity were not classified as FTS due to absence of FTS clause in India-Thailand DTAA. The AO was directed to delete the addition u/s 40(a)(ia). However, payments to a German entity were deemed FTS under India-Germany DTAA, upholding the addition u/s 40(a)(i). The appeal was partly allowed.
The Appellate Tribunal addressed various Transfer Pricing (TP) issues. It directed the AO/TPO to consider only operating profit/cost for TP adjustment in IT enabled Services transactions. For interest on trade receivables, it mandated using market determined rates. Regarding TDS u/s 195, payments to a Thailand entity were not classified as FTS due to absence of FTS clause in India-Thailand DTAA. The AO was directed to delete the addition u/s 40(a)(ia). However, payments to a German entity were deemed FTS under India-Germany DTAA, upholding the addition u/s 40(a)(i). The appeal was partly allowed.
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