https://www.taxtmi.com/caselaws?id=306112 Transfer pricing comparability must be tested year-wise on the relevant functional profile, and acceptance or rejection of a company in another year is not conclusive; the comparable was therefore sent back for fresh examination by the AO/TPO. Foreign remittances and reimbursements, including conference fees, salary, travel, promotional and managerial cost reimbursements, and passed-through discounts, were treated as not attracting TDS where treaty provisions, absence of permanent establishment, the make-available test for technical services, or the reimbursement character negated taxable income; the section 40(a)(i) disallowance was deleted. Amounts booked in an earlier financial year but remitted in the relevant year were also held outside the relevant year's disallowance, and that addition was deleted. en-us Fri, 10 Jan 2020 00:00:00 +0530 Wed, 11 Jan 2023 08:47:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306112 Transfer pricing comparability must be tested year-wise on the relevant functional profile, and acceptance or rejection of a company in another year is not conclusive; the comparable was therefore sent back for fresh examination by the AO/TPO. Foreign remittances and reimbursements, including conference fees, salary, travel, promotional and managerial cost reimbursements, and passed-through discounts, were treated as not attracting TDS where treaty provisions, absence of permanent establishment, the make-available test for technical services, or the reimbursement character negated taxable income; the section 40(a)(i) disallowance was deleted. Amounts booked in an earlier financial year but remitted in the relevant year were also held outside the relevant year's disallowance, and that addition was deleted. Case-Laws Income Tax Fri, 10 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306112