https://www.taxtmi.com/caselaws?id=416017 Transfer pricing adjustment in the manufacturing segment was held to be confined to international transactions with associated enterprises, not to entity-level results; the matter was remitted to restrict the adjustment accordingly. The Tribunal also held that payments for access to a centralized and integrated IT infrastructure facility amounted to royalty under section 9(1)(vi) and the relevant treaty, because the payment was for use of equipment rather than standalone services. On that basis, the corresponding disallowance under section 40(a)(ia) was upheld for the royalty-related component. en-us Mon, 13 Dec 2021 00:00:00 +0530 Thu, 03 Mar 2022 16:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=416017 Transfer pricing adjustment in the manufacturing segment was held to be confined to international transactions with associated enterprises, not to entity-level results; the matter was remitted to restrict the adjustment accordingly. The Tribunal also held that payments for access to a centralized and integrated IT infrastructure facility amounted to royalty under section 9(1)(vi) and the relevant treaty, because the payment was for use of equipment rather than standalone services. On that basis, the corresponding disallowance under section 40(a)(ia) was upheld for the royalty-related component. Case-Laws Income Tax Mon, 13 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=416017