https://www.taxtmi.com/caselaws?id=755411 APA methodology for a later year may have persuasive value in transfer pricing analysis, but it is not mechanically binding for the year under review; the IT segment was therefore remanded for fresh arm's length consideration. The ITeS comparables were rejected as functionally dissimilar to a low-risk captive service provider, and the distribution segment also required fresh benchmarking after segregation. Rejection of books was not sustained because no adverse defect was shown. An Indian distributor acting on its own account did not constitute a dependent agent PE of the non-resident, and payments for online advertisement space were not royalty or fees for technical services. The settled 10A computation principle on parity between export turnover and total turnover was applied, while the additional ITeS deduction issue was remanded for verification. en-us Fri, 22 Dec 2023 00:00:00 +0530 Fri, 12 Jul 2024 07:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755411 APA methodology for a later year may have persuasive value in transfer pricing analysis, but it is not mechanically binding for the year under review; the IT segment was therefore remanded for fresh arm's length consideration. The ITeS comparables were rejected as functionally dissimilar to a low-risk captive service provider, and the distribution segment also required fresh benchmarking after segregation. Rejection of books was not sustained because no adverse defect was shown. An Indian distributor acting on its own account did not constitute a dependent agent PE of the non-resident, and payments for online advertisement space were not royalty or fees for technical services. The settled 10A computation principle on parity between export turnover and total turnover was applied, while the additional ITeS deduction issue was remanded for verification. Case-Laws Income Tax Fri, 22 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755411