https://www.taxtmi.com/caselaws?id=435833 Transfer pricing for fees linked to marketing fixed income and interest rate derivative products had to reflect the respective functions, assets and risks of the Indian marketer and the associated trading entities; the market spread could not be allocated entirely to the Indian branch merely because the transaction was executed in India. The transfer pricing adjustment was deleted. On gains from transfer of debt securities, the article notes that prior decisions treating a foreign institutional investor's purchase and sale of securities as capital gains, rather than business income, were followed for the year under appeal. The securities gains were therefore assessed as capital gains. en-us Fri, 09 Dec 2022 00:00:00 +0530 Tue, 28 Mar 2023 15:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435833 Transfer pricing for fees linked to marketing fixed income and interest rate derivative products had to reflect the respective functions, assets and risks of the Indian marketer and the associated trading entities; the market spread could not be allocated entirely to the Indian branch merely because the transaction was executed in India. The transfer pricing adjustment was deleted. On gains from transfer of debt securities, the article notes that prior decisions treating a foreign institutional investor's purchase and sale of securities as capital gains, rather than business income, were followed for the year under appeal. The securities gains were therefore assessed as capital gains. Case-Laws Income Tax Fri, 09 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435833