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 was confined to international transactions with the associated enterprise, consistent with the settled view that arm's length pricing under transfer pricing provisions cannot be extended to the assessee's entire when the dispute concerns only controlled transactions. The Tribunal also sustained directions on capacity utilisation and working capital adjustments, noting that both claims had been verified and allowed on facts, leaving no surviving grievance for interference. It further upheld uniform operating treatment of forex gain and provision write-back for transfer pricing purposes, finding no basis to depart from consistency. The Revenue's challenges on all these issues were dismissed.
Transfer pricing adjustment was confined to international transactions with the associated enterprise, consistent with the settled view that arm's length pricing under transfer pricing provisions cannot be extended to the assessee's entire when the dispute concerns only controlled transactions. The Tribunal also sustained directions on capacity utilisation and working capital adjustments, noting that both claims had been verified and allowed on facts, leaving no surviving grievance for interference. It further upheld uniform operating treatment of forex gain and provision write-back for transfer pricing purposes, finding no basis to depart from consistency. The Revenue's challenges on all these issues were dismissed.
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