https://www.taxtmi.com/caselaws?id=328416 Annual maintenance service income excluded for transfer pricing required corresponding scrutiny of related operating cost, and the matter was remitted for verification because the record did not clearly show whether the expenditure had also been excluded. Sales commission was disallowed because the assessee failed to furnish the agents' identities, addresses, details of services rendered, or supporting material for the claim. Corporate performance guarantee fee was remitted for fresh examination since the lower authorities had treated it as interest without considering the treaty position, the character of the payment, the guarantee arrangement, enforceability, place of performance, and possible permanent establishment implications. en-us Fri, 22 Apr 2016 00:00:00 +0530 Thu, 02 Jun 2016 22:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=328416 Annual maintenance service income excluded for transfer pricing required corresponding scrutiny of related operating cost, and the matter was remitted for verification because the record did not clearly show whether the expenditure had also been excluded. Sales commission was disallowed because the assessee failed to furnish the agents' identities, addresses, details of services rendered, or supporting material for the claim. Corporate performance guarantee fee was remitted for fresh examination since the lower authorities had treated it as interest without considering the treaty position, the character of the payment, the guarantee arrangement, enforceability, place of performance, and possible permanent establishment implications. Case-Laws Income Tax Fri, 22 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=328416