https://www.taxtmi.com/caselaws?id=331617 Segmental results based on actual allocation were accepted for transfer pricing where project work was treated as a separate profit centre and non-project expenses were incurred for a distinct business purpose; the absence of a separate revenue stream was not, by itself, a valid basis to reject that method. The prior acceptance of the same approach in earlier and later years also supported consistency, so the transfer pricing allocation was remanded for fresh examination. Reimbursement of recruitment expenses to a non-resident parent was not disallowable under section 40(a)(i) because the payment did not contain taxable income in India, the treaty "make available" condition was not met, and no withholding obligation arose under section 195. en-us Mon, 25 Jul 2016 00:00:00 +0530 Mon, 29 Aug 2016 11:29:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=331617 Segmental results based on actual allocation were accepted for transfer pricing where project work was treated as a separate profit centre and non-project expenses were incurred for a distinct business purpose; the absence of a separate revenue stream was not, by itself, a valid basis to reject that method. The prior acceptance of the same approach in earlier and later years also supported consistency, so the transfer pricing allocation was remanded for fresh examination. Reimbursement of recruitment expenses to a non-resident parent was not disallowable under section 40(a)(i) because the payment did not contain taxable income in India, the treaty "make available" condition was not met, and no withholding obligation arose under section 195. Case-Laws Income Tax Mon, 25 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=331617