https://www.taxtmi.com/caselaws?id=253532 Allocation of common expenses between export (STPI) and domestic units by employee head-count was upheld as a permissible apportionment method and remitted for verification; exclusion of communication expenses from export turnover was maintained. Payments labelled as reimbursements for software services lacked evidence of absence of profit element and, since TDS was not deducted, were disallowed under tax withholding provisions. For transfer pricing, foreign exchange gains on receipts for software services to associated enterprises must be included in operating income when computing margins (assessed margin 12.67% adopted). Several proposed comparables were excluded as functionally dissimilar; TNMM was held appropriate for spare parts custodian transactions; administrative and marketing support charges were upheld as arm's length, with forex gains to be considered. en-us Thu, 14 Aug 2014 00:00:00 +0530 Thu, 05 Feb 2026 18:18:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=253532 Allocation of common expenses between export (STPI) and domestic units by employee head-count was upheld as a permissible apportionment method and remitted for verification; exclusion of communication expenses from export turnover was maintained. Payments labelled as reimbursements for software services lacked evidence of absence of profit element and, since TDS was not deducted, were disallowed under tax withholding provisions. For transfer pricing, foreign exchange gains on receipts for software services to associated enterprises must be included in operating income when computing margins (assessed margin 12.67% adopted). Several proposed comparables were excluded as functionally dissimilar; TNMM was held appropriate for spare parts custodian transactions; administrative and marketing support charges were upheld as arm's length, with forex gains to be considered. Case-Laws Income Tax Thu, 14 Aug 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253532