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...
Reimbursement of salary cost for seconded employees was not taxable as fees for technical services where the secondees worked under the control of the Indian entity and the payment contained no separate service element. Applying the earlier ruling in the group concern case, the ITAT found no material factual distinction for the year under consideration and treated the receipt as falling within the employer-employee salary exclusion. The addition made on that basis was deleted. The challenge to the validity of the assessment order was not pressed and was therefore not admitted.
Reimbursement of salary cost for seconded employees was not taxable as fees for technical services where the secondees worked under the control of the Indian entity and the payment contained no separate service element. Applying the earlier ruling in the group concern case, the ITAT found no material factual distinction for the year under consideration and treated the receipt as falling within the employer-employee salary exclusion. The addition made on that basis was deleted. The challenge to the validity of the assessment order was not pressed and was therefore not admitted.
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