Programme production and copyright assignment can be separately taxed when the agreement shows distinct production activity on behalf of the broadcast...
Transshipment permission for courier import goods granted subject to customs supervision, bond compliance, sealing, escort and destination acknowledgm...
The Tribunal held that comparables lacking functional similarity were to be excluded, while Keystone Integrated Marketing Services Pvt. Ltd. had to be included because the DRP had already directed its inclusion. Pass-through third-party costs in the contract R&D segment, incurred without value addition and recovered on a cost-to-cost basis, were excluded from the PLI computation and the related transfer pricing addition was deleted. Working capital adjustment was recognised as an accepted TP adjustment and directed to be verified on actuals. The DRP's direction to set off contract R&D income against royalty attribution was binding on the AO, so the adjustment was reduced accordingly. Arithmetical errors and foreign tax credit claims were remanded for verification and recomputation.
The Tribunal held that comparables lacking functional similarity were to be excluded, while Keystone Integrated Marketing Services Pvt. Ltd. had to be included because the DRP had already directed its inclusion. Pass-through third-party costs in the contract R&D segment, incurred without value addition and recovered on a cost-to-cost basis, were excluded from the PLI computation and the related transfer pricing addition was deleted. Working capital adjustment was recognised as an accepted TP adjustment and directed to be verified on actuals. The DRP's direction to set off contract R&D income against royalty attribution was binding on the AO, so the adjustment was reduced accordingly. Arithmetical errors and foreign tax credit claims were remanded for verification and recomputation.
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