Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
ITAT partially allowed assessee's appeal, affirming arm's-length royalty payments and consultancy service expenses based on consistent prior year rulings. The tribunal directed deletion of transfer pricing adjustments related to expatriate costs and reimbursements. Regarding income tax liability provision, the tribunal accepted the assessee's contention that reversal of previously disallowed provision should not result in double taxation, allowing the ground subject to AO's verification. The decision upholds procedural fairness and prevents duplicative tax treatment of contingent liabilities.
ITAT partially allowed assessee's appeal, affirming arm's-length royalty payments and consultancy service expenses based on consistent prior year rulings. The tribunal directed deletion of transfer pricing adjustments related to expatriate costs and reimbursements. Regarding income tax liability provision, the tribunal accepted the assessee's contention that reversal of previously disallowed provision should not result in double taxation, allowing the ground subject to AO's verification. The decision upholds procedural fairness and prevents duplicative tax treatment of contingent liabilities.
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