Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
ITAT remanded certain TP issues to the AO/TPO: additional evidence submitted by the assessee must be verified and the TPO shall determine benefit and compute ALP adopting TNMM in accordance with s.92C and Rules 10B/10C, affording the assessee hearing. The TPO exceeded jurisdiction by itemising assets in a slump sale and applying s.50C; the Tribunal directed acceptance of DCF valuation and the Form 3CEA fair value under s.50B. Selection of specified comparables for IPS division was upheld. Reimbursements by the assessee to its AE are cost-to-cost with no separate mark-up. Disallowance of provisions for contract losses was sustained; reversal is partly allowed subject to AO's verification of creation year and linkage to the disallowed provision.
ITAT remanded certain TP issues to the AO/TPO: additional evidence submitted by the assessee must be verified and the TPO shall determine benefit and compute ALP adopting TNMM in accordance with s.92C and Rules 10B/10C, affording the assessee hearing. The TPO exceeded jurisdiction by itemising assets in a slump sale and applying s.50C; the Tribunal directed acceptance of DCF valuation and the Form 3CEA fair value under s.50B. Selection of specified comparables for IPS division was upheld. Reimbursements by the assessee to its AE are cost-to-cost with no separate mark-up. Disallowance of provisions for contract losses was sustained; reversal is partly allowed subject to AO's verification of creation year and linkage to the disallowed provision.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
