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...
Transfer pricing adjustment arising from royalty payments requires benchmarking by the most appropriate traditional transaction method; where exact identical comparables exist the CUP method should be applied, but selected comparables must be functionally comparable and not mere local manufacturers or brand developers. The impugned comparables were held inappropriate and the matter is remitted to AO/TPO to re-benchmark afresh after affording the assessee hearing and considering the submitted TPAR; if no exact comparables receiving bundled services are found, benchmarking should proceed under TNMM using proper comparables.
Transfer pricing adjustment arising from royalty payments requires benchmarking by the most appropriate traditional transaction method; where exact identical comparables exist the CUP method should be applied, but selected comparables must be functionally comparable and not mere local manufacturers or brand developers. The impugned comparables were held inappropriate and the matter is remitted to AO/TPO to re-benchmark afresh after affording the assessee hearing and considering the submitted TPAR; if no exact comparables receiving bundled services are found, benchmarking should proceed under TNMM using proper comparables.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
