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 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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