https://www.taxtmi.com/caselaws?id=252568 In a low-risk intermediary or sogo shosha model, Berry Ratio may be an appropriate profit level indicator for the trading segment because inventory exposure and ordinary trader comparability are not meaningful, while unsupported objections based on intangibles, locational savings, or accounting differences do not displace the method. For the commission or service segment, the cost base must be confined to the assessee's own costs, so associated enterprise costs cannot be added notionally. For payments to non-residents, section 40(a)(i) disallowance does not survive where the recipient has no permanent establishment or taxable nexus in India, and relief is also recognised where the recipient has already offered the income to tax. en-us Tue, 21 Oct 2014 00:00:00 +0530 Sat, 05 Mar 2016 18:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252568 In a low-risk intermediary or sogo shosha model, Berry Ratio may be an appropriate profit level indicator for the trading segment because inventory exposure and ordinary trader comparability are not meaningful, while unsupported objections based on intangibles, locational savings, or accounting differences do not displace the method. For the commission or service segment, the cost base must be confined to the assessee's own costs, so associated enterprise costs cannot be added notionally. For payments to non-residents, section 40(a)(i) disallowance does not survive where the recipient has no permanent establishment or taxable nexus in India, and relief is also recognised where the recipient has already offered the income to tax. Case-Laws Income Tax Tue, 21 Oct 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252568