Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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