The TPO made adjustment for payments made towards intra-group services and payment made towards import of capital goods amounting to Rs.12,40,40,466/-, after accepting ALP of all other transactions under TNMM. The assessee had clubbed all the international transactions together and adopted TNMM for benchmarking. The Tribunal held that the TPO was not justified in selectively […]
DIMENSION DATA ASIA PACIFIC PTE LTD. VS. DCIT [2018] 99 taxmann.com 270 (Mumbai); TS-604-ITAT-2018 (Mumbai Tribunal)
The Tribunal held that presence of employees is to be tested separately for each type of service for computing Service PE threshold. The Tribunal further held that application of beneficial provisions of the Act for one source of income and treaty for another source of income is permissible FACTS The Assessee is a private limited […]