ITAT held that no mark-up required for actual costs allocated to eligible unit absent service element

Case Name: Finolex Cables Ltd [TS-319-ITAT-2023(PUN)-TP] Facts: The assessee was engaged in manufacturing and sales of electrical cables, optical fiber cables, lamps and switches etc. For AY 2013-14, the assessee allocated expenses to its FCL-Roorkee Unit (eligible 80-IC unit) and explained that these expenses were allocated on turnover basis except the derivative losses and interest, […]

SC held that Question as to what proportion of Profit is attributable to India is question of fact

Director of Income-tax v. Travelport Inc. – [2023] 149 470 (SC) Facts: The taxpayers are engaged in the business of providing electronic global distribution services to Airlines through “Computerized Reservation System” (CRS). The taxpayers maintain and operate a Master Computer System consisting of several main frame computers and servers located in other countries, including […]

Changing the Most Appropriate Method by the Assessee from one selected in TP Study

Section 92C(1) provides that ALP of international transaction and SDT shall be determined by adopting “MAM”, having regard to the nature of transaction or class of transaction or class of associated persons or functions performed by such persons or such other relevant factors as the Board may prescribed. Rule 10C lays down the guiding principles […]

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