Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
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Certified segmental financials used in transfer pricing documentation could not be rejected merely for differing from AS-17 audited segment disclosure where the assessee explained the allocation method and no specific defect was found; the issue was remitted for fresh consideration. ECB interest at LIBOR plus 3% was held to be at arm's length because the borrowing had RBI approval and the TPO made only ad hoc substitution without proper comparability analysis. Outstanding receivables from AEs were treated as an international transaction, and interest was directed to be recomputed invoice-to-invoice at LIBOR plus 200 basis points in line with earlier years. The direction to verify brought-forward amalgamation losses and allow them according to law was upheld.
Certified segmental financials used in transfer pricing documentation could not be rejected merely for differing from AS-17 audited segment disclosure where the assessee explained the allocation method and no specific defect was found; the issue was remitted for fresh consideration. ECB interest at LIBOR plus 3% was held to be at arm's length because the borrowing had RBI approval and the TPO made only ad hoc substitution without proper comparability analysis. Outstanding receivables from AEs were treated as an international transaction, and interest was directed to be recomputed invoice-to-invoice at LIBOR plus 200 basis points in line with earlier years. The direction to verify brought-forward amalgamation losses and allow them according to law was upheld.
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