https://www.taxtmi.com/caselaws?id=444172 Transfer pricing adjustments cannot be applied to qualifying ship operations whose income is computed under the Tonnage Tax Scheme; Chapter X does not extend to items outside the special tonnage-based computation, so the adjustment was deleted for the qualifying segment. Head office expenses allocated to qualifying activities under the same scheme also could not be sustained as transfer pricing additions, and only the non-qualifying segment remained open to examination, so that adjustment was deleted. The MFN clause in the India-Netherlands treaty did not entitle a domestic company to claim refund of Dividend Distribution Tax by relying on the India-Hungary treaty, because the treaty language protected distributed profits in shareholders' hands and did not extend treaty status to the dividend-paying company, so the refund claim failed. en-us Wed, 20 Sep 2023 00:00:00 +0530 Wed, 11 Oct 2023 12:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444172 Transfer pricing adjustments cannot be applied to qualifying ship operations whose income is computed under the Tonnage Tax Scheme; Chapter X does not extend to items outside the special tonnage-based computation, so the adjustment was deleted for the qualifying segment. Head office expenses allocated to qualifying activities under the same scheme also could not be sustained as transfer pricing additions, and only the non-qualifying segment remained open to examination, so that adjustment was deleted. The MFN clause in the India-Netherlands treaty did not entitle a domestic company to claim refund of Dividend Distribution Tax by relying on the India-Hungary treaty, because the treaty language protected distributed profits in shareholders' hands and did not extend treaty status to the dividend-paying company, so the refund claim failed. Case-Laws Income Tax Wed, 20 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444172