https://www.taxtmi.com/caselaws?id=357235 Transfer pricing comparables in the technical services and back office support segments were partly rejected or remanded where they were functionally dissimilar, persistent loss-makers, or lacked reliable segmental data, and the claim for working capital and risk adjustment was restored for reconsideration on the transfer pricing study and margin computation. The ad hoc disallowance of entertainment expenditure was deleted because it was made on a percentage basis without proper examination of the supporting evidence. The section 40(a)(i) disallowance on global support service fees paid to EMCAP was also deleted because the services were administrative and support in nature and did not satisfy the make-available test under the treaty. en-us Wed, 21 Feb 2018 00:00:00 +0530 Fri, 03 Aug 2018 17:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=357235 Transfer pricing comparables in the technical services and back office support segments were partly rejected or remanded where they were functionally dissimilar, persistent loss-makers, or lacked reliable segmental data, and the claim for working capital and risk adjustment was restored for reconsideration on the transfer pricing study and margin computation. The ad hoc disallowance of entertainment expenditure was deleted because it was made on a percentage basis without proper examination of the supporting evidence. The section 40(a)(i) disallowance on global support service fees paid to EMCAP was also deleted because the services were administrative and support in nature and did not satisfy the make-available test under the treaty. Case-Laws Income Tax Wed, 21 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=357235