https://www.taxtmi.com/caselaws?id=302124 The note explains that a MAP-settled transfer pricing margin under the India-UK DTAA was applied across the assessee's international transactions where no factual distinction existed, eliminating any transfer pricing adjustment. It also records that lease rentals on vehicles acquired under a finance lease were treated as deductible revenue expenditure on the facts. Certain matters, including expat salary reimbursements, written-back liabilities, and short grant of TDS credit, were sent back for fresh verification because the record required further examination. For Section 10A, expenditure excluded from export turnover was required to be excluded from total turnover as well, in line with binding Supreme Court authority. en-us Mon, 25 Oct 2021 00:00:00 +0530 Thu, 05 May 2022 20:59:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=302124 The note explains that a MAP-settled transfer pricing margin under the India-UK DTAA was applied across the assessee's international transactions where no factual distinction existed, eliminating any transfer pricing adjustment. It also records that lease rentals on vehicles acquired under a finance lease were treated as deductible revenue expenditure on the facts. Certain matters, including expat salary reimbursements, written-back liabilities, and short grant of TDS credit, were sent back for fresh verification because the record required further examination. For Section 10A, expenditure excluded from export turnover was required to be excluded from total turnover as well, in line with binding Supreme Court authority. Case-Laws Income Tax Mon, 25 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=302124