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 notes state that the project office performed limited technical-support functions, while principal deliverables, functions and risks remained with the Italian head office. Its transactional net margin method study showed a margin above the comparable arm's length range, with no demonstrated defect in the method or comparables and no contrary analysis. Accordingly, an ad hoc allocation of gross receipts was unsustainable; no further income was 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 notes state that the project office performed limited technical-support functions, while principal deliverables, functions and risks remained with the Italian head office. Its transactional net margin method study showed a margin above the comparable arm's length range, with no demonstrated defect in the method or comparables and no contrary analysis. Accordingly, an ad hoc allocation of gross receipts was unsustainable; no further income was attributable to the project office. Case-Laws Income Tax Fri, 29 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796076