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...
Applying a 25% related-party transaction filter, the Tribunal excluded Liquidhub Analytics Private Limited because its RPT level exceeded the prescribed threshold and it could not be treated as an uncontrolled comparable. It held that the search matrix is only a tool for identifying comparables, so rejection of the assessee's proposed comparables merely for absence from that matrix was unsustainable; the matter was remitted for fresh FAR analysis and filter-based examination. The Tribunal also required parity between cost and revenue in ESOP reimbursement under a cost-plus model, directed fresh working capital adjustment analysis, and upheld receivables adjustment in principle while requiring recomputation at LIBOR plus 200 basis points for delay beyond the agreed credit period.
Applying a 25% related-party transaction filter, the Tribunal excluded Liquidhub Analytics Private Limited because its RPT level exceeded the prescribed threshold and it could not be treated as an uncontrolled comparable. It held that the search matrix is only a tool for identifying comparables, so rejection of the assessee's proposed comparables merely for absence from that matrix was unsustainable; the matter was remitted for fresh FAR analysis and filter-based examination. The Tribunal also required parity between cost and revenue in ESOP reimbursement under a cost-plus model, directed fresh working capital adjustment analysis, and upheld receivables adjustment in principle while requiring recomputation at LIBOR plus 200 basis points for delay beyond the agreed credit period.
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