Ex parte injunction service requirements were substantially met, while civil recovery and SFIO investigation into provident fund defalcation continued...
Enforcement of resolution-plan directions continues without a Supreme Court stay, preventing suspension of redistribution and escrowed-fund distributi...
Third-party ownership claims over attached property require Special Court adjudication where purchasers lack registered sale deeds and bona fides rema...
Pure-agent reimbursements in clearing and forwarding services are excluded from taxable value when qualifying third-party payments are properly record...
Customs relief for Strait of Hormuz maritime disruptions remains available, with existing conditions continuing unchanged through the extended validit...
In transfer pricing for resale of software subscriptions, the Tribunal held that the assessee was a limited-risk, stripped-down distributor and not a marketing support service provider, because it bought software subscriptions from its associated enterprise and resold them to unrelated customers without modifying or adding value to the product. On that factual basis, the cost of software licences could not displace Berry ratio as the appropriate base, since the assessee did not own intangibles and earned only a resale margin. TNMM was upheld as the most appropriate method and Berry ratio was accepted as the correct profit level indicator for determining arm's length price, so the transfer pricing adjustment failed.
In transfer pricing for resale of software subscriptions, the Tribunal held that the assessee was a limited-risk, stripped-down distributor and not a marketing support service provider, because it bought software subscriptions from its associated enterprise and resold them to unrelated customers without modifying or adding value to the product. On that factual basis, the cost of software licences could not displace Berry ratio as the appropriate base, since the assessee did not own intangibles and earned only a resale margin. TNMM was upheld as the most appropriate method and Berry ratio was accepted as the correct profit level indicator for determining arm's length price, so the transfer pricing adjustment failed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
