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The assessee's reliance on Adobe Systems Incorporated (supra), is once again, incorrect. In that case, the reasons to believe referred to income-escapement arising from the transfer pricing analysis leading to inadequate compensation arising from a cost-plus model, whereas the Revenue's contention was premised on a greater share of income in the hands of the non-resident company as decided through the use of the Profit Split Method. As discussed above, the disposal test is satisfied in the instant case.