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TP - Mere broad functional similarity is insufficient for reliable analysis, even under Transactional Net Margin Method: ITAT (See Breaking News)

TP - AMP expenses cannot be benchmarked independently once entity-level TNMM has been applied, as segregating such expenses would result in double counting & contravene transfer pricing rules: ITAT (See Breaking News)

TP - A per settled legal position, incidental benefit to an AE does not convert routine AMP expenditure into an international transaction: ITAT (See Breaking News)

TP - Once international transaction is covered by binding APA, tax authorities can't make a disallowance u/s 37(1) on basis that expenditure was not incurred wholly & exclusively for purpose of business: ITAT (See Breaking News)

DTAA - Purpose of Art 25(1) of DTAA is limited to elimination of double taxation and cannot be interpreted to impose restrictions of domestic law on specific computational mechanism provided in Art 7(3) : ITAT SB (See Breaking News)

I-T - Apportionment of contract price into different cost centers and milestones, as pre-requisite of tender conditions, does not automatically render those activities severable from main object of contract: ITAT (See Breaking News)

I-T - If right to show cricket matches is confined to live telecast and payment made is only for matches held in series and not subsequent matches, such amount paid for transmission can't be considered as royalty: HC (See Breaking News)

I-T - Once receipts fall within definition of FTS under DTAA as well as domestic law, it becomes immaterial whether assessee has PE in India or not: ITAT (See Breaking News)

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