https://www.taxtmi.com/caselaws?id=763678 Transfer pricing adjustments for services to HLPL and SIMPL were examined against objections based on base erosion, revenue neutrality, mirror ALP and treaty protection; the commentary notes that a corresponding adjustment is not required merely because the AE's transaction was accepted elsewhere, while the HLPL benchmarking required fresh review on the fixed-versus-optional services comparison. Software licence receipts were treated as not constituting royalty in light of Supreme Court software-payment principles. Global P&T functional services to SIMPL and other service receipts to HLPL and L&T were analysed under the India-Netherlands treaty and section 9(1)(vii), with the make available test and the overseas-source exclusion leading to non-taxability as fees for technical services. en-us Wed, 18 Dec 2024 00:00:00 +0530 Tue, 24 Dec 2024 17:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763678 Transfer pricing adjustments for services to HLPL and SIMPL were examined against objections based on base erosion, revenue neutrality, mirror ALP and treaty protection; the commentary notes that a corresponding adjustment is not required merely because the AE's transaction was accepted elsewhere, while the HLPL benchmarking required fresh review on the fixed-versus-optional services comparison. Software licence receipts were treated as not constituting royalty in light of Supreme Court software-payment principles. Global P&T functional services to SIMPL and other service receipts to HLPL and L&T were analysed under the India-Netherlands treaty and section 9(1)(vii), with the make available test and the overseas-source exclusion leading to non-taxability as fees for technical services. Case-Laws Income Tax Wed, 18 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763678