https://www.taxtmi.com/caselaws?id=332142 MAP pricing accepted for US associated enterprise transactions could not be applied automatically to non-US transactions without a fresh Functional-Asset-Risk comparison; the transfer pricing matter was therefore restored for reconsideration, with liberty to adopt the MAP price if comparability was established. For section 10A computation, telecommunication expenses excluded from export turnover also had to be excluded from total turnover to preserve parity in the deduction formula; the computation was therefore to be made on the same basis for both components. en-us Fri, 22 Jul 2016 00:00:00 +0530 Sat, 15 Nov 2025 11:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=332142 MAP pricing accepted for US associated enterprise transactions could not be applied automatically to non-US transactions without a fresh Functional-Asset-Risk comparison; the transfer pricing matter was therefore restored for reconsideration, with liberty to adopt the MAP price if comparability was established. For section 10A computation, telecommunication expenses excluded from export turnover also had to be excluded from total turnover to preserve parity in the deduction formula; the computation was therefore to be made on the same basis for both components. Case-Laws Income Tax Fri, 22 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=332142