Restricted silver imports may clear under a valid import authorisation without additional status or exchange-routing requirements unless expressly imp...
Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability in transfer pricing is a factual, data-driven assessment that must conform to Rule 10B. The High Court upheld the exclusion of an outsourced-service provider from the comparable set because outsourcing a major portion of its work made it functionally dissimilar to the assessee. The Revenue produced no contrary material and failed to establish perversity, reliance on irrelevant material, or exclusion of relevant material in the Tribunal's factual finding. The substantial questions of law were answered for the assessee, and the Revenue's appeal was dismissed.
Functional comparability in transfer pricing is a factual, data-driven assessment that must conform to Rule 10B. The High Court upheld the exclusion of an outsourced-service provider from the comparable set because outsourcing a major portion of its work made it functionally dissimilar to the assessee. The Revenue produced no contrary material and failed to establish perversity, reliance on irrelevant material, or exclusion of relevant material in the Tribunal's factual finding. The substantial questions of law were answered for the assessee, and the Revenue's appeal was dismissed.
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TaxTMI 
TaxTMI 
of 4905 
