https://www.taxtmi.com/caselaws?id=796076 Attribution of offshore income to an Indian project office must follow an arm's length functions, assets and risks analysis where dealings with the head office constitute an international transaction. The project office performed limited on-site technical support under Italian head-office control, while principal deliverables, functions and risks remained in Italy. Its transactional net margin method study showed remuneration above the comparable arm's length range, with no identified defect in the method or comparables and no contrary analysis. An ad hoc allocation of gross receipts was therefore unsustainable, resulting in no further income being attributable to the project office. en-us Fri, 29 May 2026 00:00:00 +0530 Fri, 31 Jul 2026 08:27:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796076 Attribution of offshore income to an Indian project office must follow an arm's length functions, assets and risks analysis where dealings with the head office constitute an international transaction. The project office performed limited on-site technical support under Italian head-office control, while principal deliverables, functions and risks remained in Italy. Its transactional net margin method study showed remuneration above the comparable arm's length range, with no identified defect in the method or comparables and no contrary analysis. An ad hoc allocation of gross receipts was therefore unsustainable, resulting in no further income being attributable to the project office. Case-Laws Income Tax Fri, 29 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796076