https://www.taxtmi.com/caselaws?id=253326 Transfer pricing analysis accepted that the CPD and SPD trading divisions should not be artificially segregated where functions, assets, risks and comparables were materially identical, so the related adjustments were deleted. Reimbursement of advertisement expenditure from associated enterprises was treated as operating revenue in the profit level indicator because the contractual understanding and past conduct supported reimbursement and the expense intensity had to be reflected in comparability. Allocation of unallocated head-office expenses to the ISD division was held unreasonable on the facts, while current-year data was confirmed as the proper basis for arm's length price testing under Rule 10B(4). With the underlying additions deleted, the penalty under section 271(1)(c) could not survive. en-us Tue, 18 Nov 2014 00:00:00 +0530 Fri, 21 Nov 2014 12:13:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=253326 Transfer pricing analysis accepted that the CPD and SPD trading divisions should not be artificially segregated where functions, assets, risks and comparables were materially identical, so the related adjustments were deleted. Reimbursement of advertisement expenditure from associated enterprises was treated as operating revenue in the profit level indicator because the contractual understanding and past conduct supported reimbursement and the expense intensity had to be reflected in comparability. Allocation of unallocated head-office expenses to the ISD division was held unreasonable on the facts, while current-year data was confirmed as the proper basis for arm's length price testing under Rule 10B(4). With the underlying additions deleted, the penalty under section 271(1)(c) could not survive. Case-Laws Income Tax Tue, 18 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253326