https://www.taxtmi.com/caselaws?id=259196 Closely linked software development transactions may be aggregated for transfer pricing comparability where the work is composite and carried out by an integrated team, so isolated man-hour rates cannot sustain the adjustment; the matter was remanded for recomputation on an aggregated basis. The TDS write-off was allowed as business loss where tax had already been offered but credit was not received, while staff advances and advances written off in relation to the Australia subsidiary were remanded for factual verification. Interest-free advances to an associated enterprise were benchmarked using LIBOR-based pricing, with the arm's length rate directed at LIBOR plus 2%. Foreign currency technical consultancy and communication expenses were required to be excluded from total turnover under section 10A, and the revenue challenge failed. en-us Fri, 13 Feb 2015 00:00:00 +0530 Mon, 04 May 2015 06:42:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259196 Closely linked software development transactions may be aggregated for transfer pricing comparability where the work is composite and carried out by an integrated team, so isolated man-hour rates cannot sustain the adjustment; the matter was remanded for recomputation on an aggregated basis. The TDS write-off was allowed as business loss where tax had already been offered but credit was not received, while staff advances and advances written off in relation to the Australia subsidiary were remanded for factual verification. Interest-free advances to an associated enterprise were benchmarked using LIBOR-based pricing, with the arm's length rate directed at LIBOR plus 2%. Foreign currency technical consultancy and communication expenses were required to be excluded from total turnover under section 10A, and the revenue challenge failed. Case-Laws Income Tax Fri, 13 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259196