https://www.taxtmi.com/caselaws?id=439341 A delayed cross-objection filed after more than 1,212 days was treated as time-barred, but the respondent's right under Rule 27 of the ITAT Rules to support the impugned order on any decided ground was held maintainable. On the tax issues, interest remitted by an Indian branch to its head office was held not chargeable in India, so no TDS arose under section 195 and disallowance under section 40(a)(i) could not stand. The related transfer pricing adjustments on interest, liaison services, and agency services were examined through functional comparability and operating-margin analysis, and the appellate recomputations were sustained. en-us Mon, 27 Feb 2023 00:00:00 +0530 Mon, 19 Jun 2023 16:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439341 A delayed cross-objection filed after more than 1,212 days was treated as time-barred, but the respondent's right under Rule 27 of the ITAT Rules to support the impugned order on any decided ground was held maintainable. On the tax issues, interest remitted by an Indian branch to its head office was held not chargeable in India, so no TDS arose under section 195 and disallowance under section 40(a)(i) could not stand. The related transfer pricing adjustments on interest, liaison services, and agency services were examined through functional comparability and operating-margin analysis, and the appellate recomputations were sustained. Case-Laws Income Tax Mon, 27 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439341