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...
SEIS-related income had been consistently treated as non-operating, so its reversal was also required to be treated similarly to preserve comparability in TNMM margin analysis. Foreign exchange fluctuation arising from realisation of export receivables was held to be intrinsically linked to publishing support services and therefore operating in nature. On that basis, the assessee's margin fell within the arm's length range and the transfer pricing adjustment on publishing support services was deleted. The Tribunal also held that working capital adjustment is a recognised comparability adjustment under TNMM and cannot be denied merely because daily data is unavailable; reasonable approximations from opening and closing balances may be used. The AO/TPO was directed to grant the adjustment, and no further TP adjustment survived on this issue.
SEIS-related income had been consistently treated as non-operating, so its reversal was also required to be treated similarly to preserve comparability in TNMM margin analysis. Foreign exchange fluctuation arising from realisation of export receivables was held to be intrinsically linked to publishing support services and therefore operating in nature. On that basis, the assessee's margin fell within the arm's length range and the transfer pricing adjustment on publishing support services was deleted. The Tribunal also held that working capital adjustment is a recognised comparability adjustment under TNMM and cannot be denied merely because daily data is unavailable; reasonable approximations from opening and closing balances may be used. The AO/TPO was directed to grant the adjustment, and no further TP adjustment survived on this issue.
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