Employee conflict disclosures and investment restrictions expand with new recusal duties, post-employment limits, and compliance reporting requirement...
Revenue-neutral domestic transfer pricing and mirror transactions justified deletion of related-party adjustments for operation, maintenance and port ...
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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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