https://www.taxtmi.com/caselaws?id=212683 A UAE free zone entity with separate corporate status and limited liability under its incorporation documents was treated as a company under section 2(17) and not as the assessee's proprietary concern, so the related addition was deleted. Transfer pricing adjustments on sales to the UAE entity and commission to a UK entity were rejected because the UAE entity was found to be a distributor bearing inventory and credit risks, and the benchmark used was not a valid comparability. The section 14A disallowance was sustained only to the extent supported by the assessee's own computation, with the balance deleted. Commission paid to a non-resident agent was held not to attract section 40(a)(ia) because no Indian operations were shown. en-us Thu, 19 Jan 2012 00:00:00 +0530 Wed, 20 Apr 2016 10:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=212683 A UAE free zone entity with separate corporate status and limited liability under its incorporation documents was treated as a company under section 2(17) and not as the assessee's proprietary concern, so the related addition was deleted. Transfer pricing adjustments on sales to the UAE entity and commission to a UK entity were rejected because the UAE entity was found to be a distributor bearing inventory and credit risks, and the benchmark used was not a valid comparability. The section 14A disallowance was sustained only to the extent supported by the assessee's own computation, with the balance deleted. Commission paid to a non-resident agent was held not to attract section 40(a)(ia) because no Indian operations were shown. Case-Laws Income Tax Thu, 19 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=212683