https://www.taxtmi.com/caselaws?id=466341 The tribunal applied the arm's length principle and directed adoption of the MAP-approved 15.32% markup as the benchmarking margin for provision of ITE services to non-U.S. associated enterprises, reasoning that identical facts and prior tribunal precedent in the assessee's earlier years require consistent treatment; consequence: AO/TPO must use 15.32% for these international transactions. On the tax incentive claim, the tribunal held that interest and other receipts must be included appropriately in the taxable base before computing the deduction under the applicable investment allowance regime, and directed the AO to allow the incentive after including such income. en-us Fri, 27 Jan 2017 00:00:00 +0530 Mon, 02 Feb 2026 20:17:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466341 The tribunal applied the arm's length principle and directed adoption of the MAP-approved 15.32% markup as the benchmarking margin for provision of ITE services to non-U.S. associated enterprises, reasoning that identical facts and prior tribunal precedent in the assessee's earlier years require consistent treatment; consequence: AO/TPO must use 15.32% for these international transactions. On the tax incentive claim, the tribunal held that interest and other receipts must be included appropriately in the taxable base before computing the deduction under the applicable investment allowance regime, and directed the AO to allow the incentive after including such income. Case-Laws Income Tax Fri, 27 Jan 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466341