Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The Income Tax Appellate Tribunal held that the export commission paid by the assessee to foreign agents in Korea and Indonesia for sales, marketing, and customer support services rendered outside India cannot be treated as fees for technical services (FTS). Consequently, no disallowance u/s 40(a)(i) is warranted for non-deduction of tax at source. Regarding transfer pricing adjustments for provision of product development and other IT services, the Tribunal directed the Transfer Pricing Officer (TPO) to include Isummation Technologies Pvt. Ltd., Sagar Soft (India) Ltd., and Yudiz Solution Pvt. Ltd. as comparables and recompute the arm's length price accordingly. For provision of sales and marketing support services, the Tribunal excluded Majestic Research Services and Solutions Ltd. from the list of comparables, directing the TPO to recompute the arm's length price after excluding this company.
The Income Tax Appellate Tribunal held that the export commission paid by the assessee to foreign agents in Korea and Indonesia for sales, marketing, and customer support services rendered outside India cannot be treated as fees for technical services (FTS). Consequently, no disallowance u/s 40(a)(i) is warranted for non-deduction of tax at source. Regarding transfer pricing adjustments for provision of product development and other IT services, the Tribunal directed the Transfer Pricing Officer (TPO) to include Isummation Technologies Pvt. Ltd., Sagar Soft (India) Ltd., and Yudiz Solution Pvt. Ltd. as comparables and recompute the arm's length price accordingly. For provision of sales and marketing support services, the Tribunal excluded Majestic Research Services and Solutions Ltd. from the list of comparables, directing the TPO to recompute the arm's length price after excluding this company.
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