Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Additional evidence bearing directly on the transfer pricing adjustment for interest on a loan to an associated enterprise was admitted, including the independent auditor's report, the RBI correspondence and order, and a Hamburg District Court liquidation order. As the subsidiary was stated to be incurring persistent losses and under liquidation, the existing 6% interest adjustment was held unsustainable without examining these materials. The matter was remitted to the Assessing Officer for fresh adjudication in accordance with law after giving the assessee an opportunity of hearing, and no final ruling on the merits of the adjustment was made.
Additional evidence bearing directly on the transfer pricing adjustment for interest on a loan to an associated enterprise was admitted, including the independent auditor's report, the RBI correspondence and order, and a Hamburg District Court liquidation order. As the subsidiary was stated to be incurring persistent losses and under liquidation, the existing 6% interest adjustment was held unsustainable without examining these materials. The matter was remitted to the Assessing Officer for fresh adjudication in accordance with law after giving the assessee an opportunity of hearing, and no final ruling on the merits of the adjustment was made.
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