https://www.taxtmi.com/caselaws?id=468496 Transfer pricing adjustment must be confined to international transactions with associated enterprises, and segmental benchmarking requires reliable commercial evidence; on that basis, the entity-level adjustment was not sustained and the EEC and ACD segment matters were remitted for fresh consideration. Business reversals, liabilities written back and provision reversals directly linked to operations were treated as operating income, while a provision for anticipated contract losses was rejected as an unascertained future loss and not an operating item. Shared service payments to a non-resident group company were held to be managerial or support services that did not make available technical knowledge or know-how, so no withholding tax under section 195 was required. en-us Fri, 17 Jun 2022 00:00:00 +0530 Sat, 09 May 2026 12:57:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468496 Transfer pricing adjustment must be confined to international transactions with associated enterprises, and segmental benchmarking requires reliable commercial evidence; on that basis, the entity-level adjustment was not sustained and the EEC and ACD segment matters were remitted for fresh consideration. Business reversals, liabilities written back and provision reversals directly linked to operations were treated as operating income, while a provision for anticipated contract losses was rejected as an unascertained future loss and not an operating item. Shared service payments to a non-resident group company were held to be managerial or support services that did not make available technical knowledge or know-how, so no withholding tax under section 195 was required. Case-Laws Income Tax Fri, 17 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468496