Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Transfer pricing on back-to-back project execution was held to be benchmarked under the CUP method rather than TNMM because the assessee acted as a project office for the foreign principal and the relevant transactions were direct services to the associated enterprise. The Tribunal treated the joint venture structure as an administrative vehicle, noted that the project results and related financials were already recorded and taxed in India, and found no realistic profit-shifting concern where the operations and reimbursements were domestic in nature. On that basis, it affirmed deletion of the transfer pricing adjustment and rejected the Revenue's challenge.
Transfer pricing on back-to-back project execution was held to be benchmarked under the CUP method rather than TNMM because the assessee acted as a project office for the foreign principal and the relevant transactions were direct services to the associated enterprise. The Tribunal treated the joint venture structure as an administrative vehicle, noted that the project results and related financials were already recorded and taxed in India, and found no realistic profit-shifting concern where the operations and reimbursements were domestic in nature. On that basis, it affirmed deletion of the transfer pricing adjustment and rejected the Revenue's challenge.
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