Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Where a dependent agent permanent establishment in India has already been remunerated at arm's length, no further profits are attributable to that permanent establishment. Applying Morgan Stanley and Honda Motors, the ITAT held that the AO's ad hoc attribution of revenue and estimation of profit under Rule 10 was unjustified because the transfer pricing study had been furnished and the arm's length nature of the transactions was neither adversely examined nor doubted. The addition for further profit attribution was deleted, and the remaining grounds were treated as academic.
Where a dependent agent permanent establishment in India has already been remunerated at arm's length, no further profits are attributable to that permanent establishment. Applying Morgan Stanley and Honda Motors, the ITAT held that the AO's ad hoc attribution of revenue and estimation of profit under Rule 10 was unjustified because the transfer pricing study had been furnished and the arm's length nature of the transactions was neither adversely examined nor doubted. The addition for further profit attribution was deleted, and the remaining grounds were treated as academic.
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