https://www.taxtmi.com/caselaws?id=750703 In transfer pricing, back-to-back inter-bank indemnity services were treated as support services, and where no reliable third-party comparable for identical services existed, TNMM was accepted as the most appropriate method rather than CUP. Interest on income-tax refund was treated as interest paid by the Government and held exempt under Article 11(3) of the India-Canada DTAA. For head office expenditure, section 44C was applied as the governing ceiling for non-resident claims, and the absence of a separate branch-book entry was held not decisive where the claim remained within the statutory limit. en-us Wed, 28 Feb 2024 00:00:00 +0530 Wed, 27 Mar 2024 17:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=750703 In transfer pricing, back-to-back inter-bank indemnity services were treated as support services, and where no reliable third-party comparable for identical services existed, TNMM was accepted as the most appropriate method rather than CUP. Interest on income-tax refund was treated as interest paid by the Government and held exempt under Article 11(3) of the India-Canada DTAA. For head office expenditure, section 44C was applied as the governing ceiling for non-resident claims, and the absence of a separate branch-book entry was held not decisive where the claim remained within the statutory limit. Case-Laws Income Tax Wed, 28 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=750703