https://www.taxtmi.com/caselaws?id=439806 Acropetal Technologies Ltd. was excluded from the transfer pricing comparables set because fraud-related irregularities and fund diversion made its margins and financial reliability doubtful. Accuspeed Engineering Ltd. and Kirloskar Consultants Ltd. were remitted for fresh verification, while Harita Techserv Ltd. was also sent back to the transfer pricing authority because the record required reconsideration of its comparability. Ocean freight paid to the Korean AE for shipment in international traffic was held to fall under the India-Korea shipping article, not as royalty or fees for technical services, so no TDS was required and the section 40(a)(i) disallowance was deleted. en-us Fri, 23 Jun 2023 00:00:00 +0530 Mon, 03 Jul 2023 08:38:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439806 Acropetal Technologies Ltd. was excluded from the transfer pricing comparables set because fraud-related irregularities and fund diversion made its margins and financial reliability doubtful. Accuspeed Engineering Ltd. and Kirloskar Consultants Ltd. were remitted for fresh verification, while Harita Techserv Ltd. was also sent back to the transfer pricing authority because the record required reconsideration of its comparability. Ocean freight paid to the Korean AE for shipment in international traffic was held to fall under the India-Korea shipping article, not as royalty or fees for technical services, so no TDS was required and the section 40(a)(i) disallowance was deleted. Case-Laws Income Tax Fri, 23 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439806