https://www.taxtmi.com/caselaws?id=399776 Where reliable segmental results are available, transfer pricing benchmarking must be confined to the tested segment, so combined trading and service figures could not be used for the smart card distribution segment. Infosys Limited and Larsen and Toubro Infotech Limited were held functionally dissimilar to a captive software development service provider and were excluded as comparables because of scale, intangibles, risk profile and lack of reliable segmental data. The disallowance under section 40(a)(i) relating to reimbursement-type payments required fresh factual verification. In principle, dividend distribution tax could not be levied above the India-Germany treaty rate, subject to verification of the treaty exception conditions. en-us Tue, 13 Oct 2020 00:00:00 +0530 Tue, 09 Dec 2025 12:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=399776 Where reliable segmental results are available, transfer pricing benchmarking must be confined to the tested segment, so combined trading and service figures could not be used for the smart card distribution segment. Infosys Limited and Larsen and Toubro Infotech Limited were held functionally dissimilar to a captive software development service provider and were excluded as comparables because of scale, intangibles, risk profile and lack of reliable segmental data. The disallowance under section 40(a)(i) relating to reimbursement-type payments required fresh factual verification. In principle, dividend distribution tax could not be levied above the India-Germany treaty rate, subject to verification of the treaty exception conditions. Case-Laws Income Tax Tue, 13 Oct 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=399776