https://www.taxtmi.com/caselaws?id=433329 The ITAT Pune determined that the assessee functioned as a marketing support services provider rather than a distribution support services entity. The tribunal analyzed the reseller agreement and found the assessee performed routine marketing activities including attending conferences and exhibitions, while the AE retained product ownership, order acceptance/rejection authority, and pricing control. The assessee retained only 3.5% of customer receipts for marketing functions. The tribunal set aside the CIT(A)'s findings and restored the TPO's order, allowing the Revenue's appeal. Additionally, the tribunal held that foreign exchange gains should be treated as operating in nature for PLI computation purposes. en-us Mon, 16 Jan 2023 00:00:00 +0530 Tue, 20 May 2025 13:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433329 The ITAT Pune determined that the assessee functioned as a marketing support services provider rather than a distribution support services entity. The tribunal analyzed the reseller agreement and found the assessee performed routine marketing activities including attending conferences and exhibitions, while the AE retained product ownership, order acceptance/rejection authority, and pricing control. The assessee retained only 3.5% of customer receipts for marketing functions. The tribunal set aside the CIT(A)'s findings and restored the TPO's order, allowing the Revenue's appeal. Additionally, the tribunal held that foreign exchange gains should be treated as operating in nature for PLI computation purposes. Case-Laws Income Tax Mon, 16 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433329