Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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ITAT held that transactions between the assessee and franchisees/LFS constitute principal-to-principal sales, not commission payments. The tribunal rejected revenue's contentions under Sections 194H and 194I, finding no evidence of commission or rental arrangement. Employees' temporary presence in LFS stores does not establish possession or control. The brand's market positioning through discounted pricing does not constitute commission. The tribunal found no merit in revenue's arguments and dismissed the appeal, upholding the lower appellate authority's order and maintaining the principal-to-principal sales characterization.
ITAT held that transactions between the assessee and franchisees/LFS constitute principal-to-principal sales, not commission payments. The tribunal rejected revenue's contentions under Sections 194H and 194I, finding no evidence of commission or rental arrangement. Employees' temporary presence in LFS stores does not establish possession or control. The brand's market positioning through discounted pricing does not constitute commission. The tribunal found no merit in revenue's arguments and dismissed the appeal, upholding the lower appellate authority's order and maintaining the principal-to-principal sales characterization.
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