https://www.taxtmi.com/caselaws?id=285884 Administrative support service charges paid to the holding company were held not to warrant disallowance under section 40A(2)(a) because the services were documented under an agreement and supported by emails, invoices and board minutes, while the charge was not shown to be unsupported or excessive. In transfer pricing, adjustment was confined to international transactions with associated enterprises and could not be extended to non-international transactions. FCI Technology Services Ltd. was directed to be included among comparables, as it was not shown to be a persistent loss-maker and its functional similarity was not disputed. The assessee's own PLI accepted in MAP proceedings could not be reopened, and ALP was to be recomputed accordingly. en-us Thu, 11 Jul 2019 00:00:00 +0530 Sat, 01 Feb 2020 07:13:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=285884 Administrative support service charges paid to the holding company were held not to warrant disallowance under section 40A(2)(a) because the services were documented under an agreement and supported by emails, invoices and board minutes, while the charge was not shown to be unsupported or excessive. In transfer pricing, adjustment was confined to international transactions with associated enterprises and could not be extended to non-international transactions. FCI Technology Services Ltd. was directed to be included among comparables, as it was not shown to be a persistent loss-maker and its functional similarity was not disputed. The assessee's own PLI accepted in MAP proceedings could not be reopened, and ALP was to be recomputed accordingly. Case-Laws Income Tax Thu, 11 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=285884