https://www.taxtmi.com/caselaws?id=775614 A foreign head office and its Indian permanent establishment were treated as separate enterprises for transfer pricing, but the PE was held to be an associated enterprise because its business in India was wholly dependent on the head office's know-how, drawings, documentation and project specifications under section 92A(2)(g). For the onshore service transaction, CUP was rejected because the relied-upon contract was not a strict uncontrolled comparable and the TNMM adopted by the TPO was upheld. Offshore supply receipts were also treated as partly attributable to Indian activities, including pre-sale, warranty, defect-liability and performance-guarantee functions, so transfer pricing adjustment was sustained. en-us Tue, 22 Jul 2025 00:00:00 +0530 Mon, 28 Jul 2025 08:27:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775614 A foreign head office and its Indian permanent establishment were treated as separate enterprises for transfer pricing, but the PE was held to be an associated enterprise because its business in India was wholly dependent on the head office's know-how, drawings, documentation and project specifications under section 92A(2)(g). For the onshore service transaction, CUP was rejected because the relied-upon contract was not a strict uncontrolled comparable and the TNMM adopted by the TPO was upheld. Offshore supply receipts were also treated as partly attributable to Indian activities, including pre-sale, warranty, defect-liability and performance-guarantee functions, so transfer pricing adjustment was sustained. Case-Laws Income Tax Tue, 22 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775614