Income Tax - Transfer Pricing, Most Appropriate Method, Functional profile of captive service provider versus trader, TNMM versus Resale Price Method - The Respondent disclosed transactions with its Associated Enterprise and adopted the Transaction Net Margin Method as the most appropriate method, c...
Income Tax – Transfer pricing adjustment on intra-group services, Arm's length price determined at Nil without applying any prescribed method, Giving effect to rectification order passed by CPC under Section 154, Disallowance under Section 36(1)(va) of employees' contribution to ESI, Adjustment on a...
Income Tax – Fixed place Permanent Establishment under Article 5 of India-US DTAA, Reliance on Form 10-K and website information, Dependent Agency Permanent Establishment under Article 5(4) of India-US DTAA and attribution of profits - Appellant is a company incorporated in the United States which s...
Income Tax – Transfer pricing, Rejection of cash PLI and exclusion of depreciation and customs duty in first year of commercial operations, Rule 10B(3) comparability adjustments, Arm's length interest rate on external commercial borrowing from Associated Enterprise, Challenge to initiation of penalt...
Income Tax – Transfer pricing, Intra-group administrative services, Reliance on Advance Pricing Agreement for year outside its period – The Respondent, engaged in merchant banking, investment advisory and stock broking services, received administrative support services from its AEs on allocation of...