https://www.taxtmi.com/caselaws?id=753540 Internal TNMM may be relevant where an assessee renders similar IT-enabled services to AE and non-AE segments, and benchmarking should focus on AE operating profit and cost data; the matter was remanded for reconsideration on that basis. Trade receivables from AEs can be separately benchmarked as an international transaction, and foreign-currency interest was directed to be computed using LIBOR plus 200 basis points. Disallowance under section 40(a)(i) for Japan payments was remanded for fresh verification of secondment and reimbursement evidence. The Thailand payment disallowance was deleted because the India-Thailand DTAA did not provide a fee for technical services article. The German payment disallowance was upheld as the evidence supported technical services and withholding obligations. en-us Fri, 31 May 2024 00:00:00 +0530 Tue, 04 Jun 2024 10:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753540 Internal TNMM may be relevant where an assessee renders similar IT-enabled services to AE and non-AE segments, and benchmarking should focus on AE operating profit and cost data; the matter was remanded for reconsideration on that basis. Trade receivables from AEs can be separately benchmarked as an international transaction, and foreign-currency interest was directed to be computed using LIBOR plus 200 basis points. Disallowance under section 40(a)(i) for Japan payments was remanded for fresh verification of secondment and reimbursement evidence. The Thailand payment disallowance was deleted because the India-Thailand DTAA did not provide a fee for technical services article. The German payment disallowance was upheld as the evidence supported technical services and withholding obligations. Case-Laws Income Tax Fri, 31 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753540