https://www.taxtmi.com/caselaws?id=358283 Functional similarity remains essential under TNMM: Apitco Ltd., Choksi Lab Ltd. and WAPCOS Ltd. were excluded because their consultancy, testing and project-based activities were materially different from the assessee's marketing and technical support services. Transfer pricing principles were held applicable to dealings between a foreign head office and its Indian branch; objections based on self-transaction, mutuality and exemption from arm's length scrutiny were rejected. The AMP adjustment based on the bright line test was not finally sustained because later precedents required reconsideration of the existence and measurement of the international transaction, so the matter was remanded for fresh determination with selling expenses kept out of AMP benchmarking. en-us Wed, 04 Apr 2018 00:00:00 +0530 Mon, 09 Apr 2018 08:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=358283 Functional similarity remains essential under TNMM: Apitco Ltd., Choksi Lab Ltd. and WAPCOS Ltd. were excluded because their consultancy, testing and project-based activities were materially different from the assessee's marketing and technical support services. Transfer pricing principles were held applicable to dealings between a foreign head office and its Indian branch; objections based on self-transaction, mutuality and exemption from arm's length scrutiny were rejected. The AMP adjustment based on the bright line test was not finally sustained because later precedents required reconsideration of the existence and measurement of the international transaction, so the matter was remanded for fresh determination with selling expenses kept out of AMP benchmarking. Case-Laws Income Tax Wed, 04 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=358283