https://www.taxtmi.com/caselaws?id=263658 The Tribunal directed the determination of Arm's Length Price (ALP) for international transactions separately for supply of raw materials and import of products, with the subvention fee set off against any transfer pricing adjustment. The characterization of transactions between the Assessee and Torrent Pharmaceuticals Ltd. was clarified, distinguishing between international transactions and those not resulting in tax base erosion in India. Disallowance under Section 40(a)(ia) was subject to verification of tax payments by TPL. Comparable companies were excluded based on functional dissimilarity, and recharacterization of services as Clinical Trial Services was remanded for further evidence consideration. The appeal was partly allowed, with specific issues remanded for fresh review. en-us Thu, 30 Jul 2015 00:00:00 +0530 Tue, 08 Sep 2015 10:27:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=263658 The Tribunal directed the determination of Arm's Length Price (ALP) for international transactions separately for supply of raw materials and import of products, with the subvention fee set off against any transfer pricing adjustment. The characterization of transactions between the Assessee and Torrent Pharmaceuticals Ltd. was clarified, distinguishing between international transactions and those not resulting in tax base erosion in India. Disallowance under Section 40(a)(ia) was subject to verification of tax payments by TPL. Comparable companies were excluded based on functional dissimilarity, and recharacterization of services as Clinical Trial Services was remanded for further evidence consideration. The appeal was partly allowed, with specific issues remanded for fresh review. Case-Laws Income Tax Thu, 30 Jul 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=263658