Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Transfer pricing adjustment on guarantee commission for SBLC issued for an AE was deleted because benchmarking by external CUP using bank guarantee commission was founded on an incorrect factual premise and, in law, bank guarantees are not comparable to corporate guarantees/SBLC for ALP determination; the assessee's "Other Method" was accepted as ALP. Transfer pricing adjustment on interest on AE loan was deleted as CUP based on the local central bank rate in the borrower's jurisdiction was the appropriate benchmark and the assessee's rate was at arm's length. Addition under s.68 r.w.s. 115BBE for an NBFC loan was deleted since identity, genuineness, and creditworthiness were proved through confirmations and banking trail. Deduction u/s 35(2AB) was allowed as per DSIR certification, brokerage on property sale was allowed as transfer expense, and s.14A disallowance was restricted to dividend-bearing investments. - ITAT
Transfer pricing adjustment on guarantee commission for SBLC issued for an AE was deleted because benchmarking by external CUP using bank guarantee commission was founded on an incorrect factual premise and, in law, bank guarantees are not comparable to corporate guarantees/SBLC for ALP determination; the assessee's "Other Method" was accepted as ALP. Transfer pricing adjustment on interest on AE loan was deleted as CUP based on the local central bank rate in the borrower's jurisdiction was the appropriate benchmark and the assessee's rate was at arm's length. Addition under s.68 r.w.s. 115BBE for an NBFC loan was deleted since identity, genuineness, and creditworthiness were proved through confirmations and banking trail. Deduction u/s 35(2AB) was allowed as per DSIR certification, brokerage on property sale was allowed as transfer expense, and s.14A disallowance was restricted to dividend-bearing investments. - ITAT
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