https://www.taxtmi.com/caselaws?id=345251 Transfer pricing under Chapter X must be benchmarked against uncontrolled comparables for the assessee's international transactions, and substituting the Associated Enterprise as the tested party in an entity-level exercise was held contrary to the statutory scheme; the transfer pricing adjustment was set aside and remitted for fresh determination. For section 10B, foreign currency expenditure excluded from export turnover was also required to be excluded from total turnover, and deduction was allowed on that basis. On-site software development executed by the Associated Enterprise was remitted for factual verification, while interest income and profit on sale of assets were held not to have the requisite direct nexus with the eligible undertaking. Disallowance under section 40(a)(i) was treated as enhanced eligible income and qualified for section 10B deduction. en-us Wed, 07 Jun 2017 00:00:00 +0530 Wed, 12 Jul 2017 07:08:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=345251 Transfer pricing under Chapter X must be benchmarked against uncontrolled comparables for the assessee's international transactions, and substituting the Associated Enterprise as the tested party in an entity-level exercise was held contrary to the statutory scheme; the transfer pricing adjustment was set aside and remitted for fresh determination. For section 10B, foreign currency expenditure excluded from export turnover was also required to be excluded from total turnover, and deduction was allowed on that basis. On-site software development executed by the Associated Enterprise was remitted for factual verification, while interest income and profit on sale of assets were held not to have the requisite direct nexus with the eligible undertaking. Disallowance under section 40(a)(i) was treated as enhanced eligible income and qualified for section 10B deduction. Case-Laws Income Tax Wed, 07 Jun 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=345251