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 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...
Software-development comparability turned on material differences in turnover, scalability, brand value, assets employed and functional, asset and risk profile. Mindtree Ltd., LTI Mindtree Ltd. and Tata Consultancy Services, having substantially greater scale and brand value than a captive service provider, were excluded from the comparable set. Interest on delayed receivables arising from foreign-currency invoices required benchmarking using LIBOR plus an appropriate mark-up, or another appropriate rate, rather than SBI rates. The resulting treatment required fresh benchmarking of interest on those receivables.
Software-development comparability turned on material differences in turnover, scalability, brand value, assets employed and functional, asset and risk profile. Mindtree Ltd., LTI Mindtree Ltd. and Tata Consultancy Services, having substantially greater scale and brand value than a captive service provider, were excluded from the comparable set. Interest on delayed receivables arising from foreign-currency invoices required benchmarking using LIBOR plus an appropriate mark-up, or another appropriate rate, rather than SBI rates. The resulting treatment required fresh benchmarking of interest on those receivables.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
