https://www.taxtmi.com/caselaws?id=248658 Income from continuous and systematic service activity for a foreign group entity is treated as business income where the activity is business-linked and has been consistently accepted in earlier years. Royalty paid for use of franchise rights is regarded as a business expenditure when incurred under the commercial arrangement for running the franchise. Administrative es allocated to a subsidiary are not disallowed on a broad attribution without a proper basis. Computer peripherals and accessories qualify for 60% depreciation as part of the computer system. In transfer pricing, comparables must be functionally similar with similar assets and risks; dissimilar businesses are excluded, and unresolved operating-expense issues may require fresh adjudication. Current-year data is the norm, and the proviso to section 92C(2) tolerance benefit was not available on the stated facts. en-us Fri, 30 May 2014 00:00:00 +0530 Thu, 19 Jun 2014 20:01:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=248658 Income from continuous and systematic service activity for a foreign group entity is treated as business income where the activity is business-linked and has been consistently accepted in earlier years. Royalty paid for use of franchise rights is regarded as a business expenditure when incurred under the commercial arrangement for running the franchise. Administrative es allocated to a subsidiary are not disallowed on a broad attribution without a proper basis. Computer peripherals and accessories qualify for 60% depreciation as part of the computer system. In transfer pricing, comparables must be functionally similar with similar assets and risks; dissimilar businesses are excluded, and unresolved operating-expense issues may require fresh adjudication. Current-year data is the norm, and the proviso to section 92C(2) tolerance benefit was not available on the stated facts. Case-Laws Income Tax Fri, 30 May 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=248658