https://www.taxtmi.com/caselaws?id=243723 The Revenue's appeal against the CIT(A)'s order for the assessment year 2004-05 was dismissed in a case involving a subsidiary engaged in software development services. The dispute centered on the allowability of expenses incurred before and after a specific agreement with an associated enterprise for mark-up calculation. The CIT(A) upheld the adjustment only for post-agreement expenses, rejecting the Revenue's argument for considering pre-agreement expenses. The decision emphasized the importance of evidence supporting the commencement of services post-agreement and highlighted compliance with the arm's length principle in determining the transfer price. en-us Sun, 30 Jan 2011 00:00:00 +0530 Sat, 08 Feb 2014 13:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=243723 The Revenue's appeal against the CIT(A)'s order for the assessment year 2004-05 was dismissed in a case involving a subsidiary engaged in software development services. The dispute centered on the allowability of expenses incurred before and after a specific agreement with an associated enterprise for mark-up calculation. The CIT(A) upheld the adjustment only for post-agreement expenses, rejecting the Revenue's argument for considering pre-agreement expenses. The decision emphasized the importance of evidence supporting the commencement of services post-agreement and highlighted compliance with the arm's length principle in determining the transfer price. Case-Laws Income Tax Sun, 30 Jan 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=243723