Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Disallowance of payments for intra-group services to an associated enterprise was examined on whether services were actually rendered and whether they were duplicative, stewardship, incidental, or on-call. Based on the nature and scale of operations, centralized group support, and audited accounts showing no double-claim of expenses, the tribunal held that the services were received and the expenditure was incurred; however, since the TPO had not examined the assessee's ALP under the prescribed approach despite TNMM being adopted, ALP determination was remanded to the TPO and the related grounds were allowed for statistical purposes. The challenge to the DRP/TPO's use of "other method" without comparables was rejected as meritless and dismissed. - ITAT
Disallowance of payments for intra-group services to an associated enterprise was examined on whether services were actually rendered and whether they were duplicative, stewardship, incidental, or on-call. Based on the nature and scale of operations, centralized group support, and audited accounts showing no double-claim of expenses, the tribunal held that the services were received and the expenditure was incurred; however, since the TPO had not examined the assessee's ALP under the prescribed approach despite TNMM being adopted, ALP determination was remanded to the TPO and the related grounds were allowed for statistical purposes. The challenge to the DRP/TPO's use of "other method" without comparables was rejected as meritless and dismissed. - ITAT
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