https://www.taxtmi.com/caselaws?id=756981 Excessive related party transactions rendered two proposed comparables functionally unreliable for transfer pricing. Since their annual reports showed 99% and 100% revenue from inter-company transactions, they were held non-comparable and directed to be excluded, with the arm's length price to be recomputed on the remaining set. Disallowance of support services cost by altering the allocation key from headcount to salary ratio was held impermissible because the headcount-based key had been consistently accepted and judicially affirmed as appropriate; the adjustment was set aside. Depreciation on identified intangibles (customer contracts and assembled workforce) was allowed at 25% as capital expenditure, and the AO was directed to grant depreciation accordingly. en-us Fri, 09 Aug 2024 00:00:00 +0530 Mon, 05 Jan 2026 12:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756981 Excessive related party transactions rendered two proposed comparables functionally unreliable for transfer pricing. Since their annual reports showed 99% and 100% revenue from inter-company transactions, they were held non-comparable and directed to be excluded, with the arm's length price to be recomputed on the remaining set. Disallowance of support services cost by altering the allocation key from headcount to salary ratio was held impermissible because the headcount-based key had been consistently accepted and judicially affirmed as appropriate; the adjustment was set aside. Depreciation on identified intangibles (customer contracts and assembled workforce) was allowed at 25% as capital expenditure, and the AO was directed to grant depreciation accordingly. Case-Laws Income Tax Fri, 09 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756981