https://www.taxtmi.com/caselaws?id=779680 A foreign enterprise and its Indian permanent establishment were treated as distinct enterprises for transfer pricing purposes, so the head office-PE arrangement was regarded as an international transaction subject to Chapter X and valid reference under section 92CA. The Tribunal sustained transfer pricing adjustments for both onshore and offshore contracts, holding that the project office acted only as the executing arm, that CUP was not a reliable comparable, and that the offshore supply had sufficient Indian nexus through guarantees, warranty, support, and repair obligations. Consequential interest under sections 234B and 234C was upheld, and penalty-initiation objections were held premature in the assessment appeal. en-us Tue, 07 Oct 2025 00:00:00 +0530 Fri, 10 Oct 2025 08:44:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779680 A foreign enterprise and its Indian permanent establishment were treated as distinct enterprises for transfer pricing purposes, so the head office-PE arrangement was regarded as an international transaction subject to Chapter X and valid reference under section 92CA. The Tribunal sustained transfer pricing adjustments for both onshore and offshore contracts, holding that the project office acted only as the executing arm, that CUP was not a reliable comparable, and that the offshore supply had sufficient Indian nexus through guarantees, warranty, support, and repair obligations. Consequential interest under sections 234B and 234C was upheld, and penalty-initiation objections were held premature in the assessment appeal. Case-Laws Income Tax Tue, 07 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779680