https://www.taxtmi.com/caselaws?id=346224 Where import of raw materials and export of finished goods were closely inter-linked, arm's length pricing was to be determined on a composite basis under TNMM rather than by applying separate methods. Depreciation could be excluded from TNMM margins only where exceptional facts showed a material difference, so the depreciation issue was remitted for fresh examination. Testing fee paid to an associated enterprise was treated as revenue expenditure, not fees for technical services, because it did not make available technical know-how or create an enduring asset. Software expenditure was also held to be revenue in nature because it was incurred for the smooth running of business and did not result in a new capital asset. en-us Mon, 31 Jul 2017 00:00:00 +0530 Wed, 09 Aug 2017 18:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=346224 Where import of raw materials and export of finished goods were closely inter-linked, arm's length pricing was to be determined on a composite basis under TNMM rather than by applying separate methods. Depreciation could be excluded from TNMM margins only where exceptional facts showed a material difference, so the depreciation issue was remitted for fresh examination. Testing fee paid to an associated enterprise was treated as revenue expenditure, not fees for technical services, because it did not make available technical know-how or create an enduring asset. Software expenditure was also held to be revenue in nature because it was incurred for the smooth running of business and did not result in a new capital asset. Case-Laws Income Tax Mon, 31 Jul 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=346224