Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
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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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