Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
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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.
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