Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Transfer pricing dispute over benchmarking of AMP expenses and appropriate ALP method: the Bright Line Test (BLT) adjustments are held legally unsustainable and deleted; the Cost Plus method is rejected as unjustified because the assessee acted as a distributor incurring routine business promotion and employee costs that should form part of trading cost; the tribunal accepts comparability under adjusted TNMM and directs an ALP uplift equal to the difference between the comparable PLI and the assessee's margin, instructing the AO to compute and apply that limited adjustment in line with the cited Sony Ericsson precedent.
Transfer pricing dispute over benchmarking of AMP expenses and appropriate ALP method: the Bright Line Test (BLT) adjustments are held legally unsustainable and deleted; the Cost Plus method is rejected as unjustified because the assessee acted as a distributor incurring routine business promotion and employee costs that should form part of trading cost; the tribunal accepts comparability under adjusted TNMM and directs an ALP uplift equal to the difference between the comparable PLI and the assessee's margin, instructing the AO to compute and apply that limited adjustment in line with the cited Sony Ericsson precedent.
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