“associated enterprise”

Transfer PricingSection 92ASection 92A2,562 judgments

The decision most relied on for associated enterprise is CIT v. EKL Appliances Ltd. (345 ITR 241), cited in 422 judgments on BharatTax.

Leading authorities on associated enterprise

CIT v. EKL Appliances Ltd.

345 ITR 241 · 2012 · High Court

422

citing judgments

Transfer pricing adjustments for outstanding receivables are permissible only if the Tax Officer establishes, through analysis over a period, a pattern indicating an international transaction intended to benefit an associated enterprise. The Tax Officer cannot question purely business decisions like royalty payments or exceed jurisdiction by applying cost-benefit analysis to determine the arm's length price of services.

Sassoon J. David & Co. Pvt. Ltd. v. CIT

118 ITR 261 · 1979 · Supreme Court

323

citing judgments

An expense incurred by an assessee for its own business, such as advertising, marketing, and promotional (AMP) expenses, cannot be disallowed merely because it incidentally or indirectly benefits the assessee's sister concerns or associated enterprises.

CIT v. Everest Kento Cylinders Ltd.

378 ITR 57 · 2015 · High Court

304

citing judgments

Corporate guarantee fees are subject to transfer pricing rules, and adjustments may be needed to account for differences between corporate guarantees and more liquid bank guarantees when determining arm's length price.

CIT v. Cotton Naturals (I) (P.) Ltd.

55 Taxmann.com 523 · 2015 · High Court

273

citing judgments

The interest rate for benchmarking foreign currency loans advanced to Associated Enterprises should be the market-determined rate applicable to the currency of the loan, such as LIBOR for US Dollar loans, rather than a domestic lending rate like the Indian PLR.

CIT v. Agnity India Technologies (P.) Ltd.

36 Taxmann.com 289 · 2013 · High Court

171

citing judgments

The Delhi High Court holds that Infosys Ltd. is not comparable to a captive software development service provider for transfer pricing analysis, given its huge turnover, high profit margins, ownership of intangible intellectual property rights, branded products, and differing risk profile.

DIT v. Morgan Stanley Co. Inc.

399 ITR 34 · 2017 · Supreme Court

162

citing judgments

Once a transfer pricing analysis has been undertaken for an Indian associated enterprise, no further profits are attributable to it as a Permanent Establishment, thereby extinguishing the need for additional profit attribution.

PCIT v. Redington (India) Ltd.

430 ITR 298 · 2021 · High Court

132

citing judgments

A corporate guarantee issued to Associated Enterprises (AEs) is an international transaction under Section 92B, requiring adjustments for guarantee commission due to inherent risk. The reasonable arm's length rate for benchmarking such corporate guarantees can be determined using internal or external comparable uncontrolled prices.

Sony India (P) Ltd. v. DCIT

114 ITD 448 · 2008 · ITAT

131

citing judgments

For transfer pricing purposes, functionally dissimilar entities that have significant business differences must be excluded from the list of comparables for benchmarking analysis. It also provides guidance on the non-allocation of advertisement, marketing, and promotion (AMP) expenses to other entities when incurred solely for the assessee's business.

Judgments citing associated enterprise

Letiwind Shriram Manufacturing Limited, Chennai vs. DCIT, Chennai

In the result, the appeal filed by the assessee is dismissed

ITA 493/CHNY/2017[2012-13]Status: DisposedITAT Chennai13 Dec 2024AY 2012-13

Bench: Shri Ss Viswanethra Ravi & Shri Jagadishआयकर अपील सं./Ita No.493/Chny/2017 िनधा;रण वष; /Assessment Year: 2012-13

For Appellant: NoneFor Respondent: Shri A. Sasikumar, CIT

Section 143(3)

engaged in the business of manufacturing MW-class wind turbine generators (WTC). During the year, the assessee-company has made purchase and sales to Associated Enterprises (AE) and third party in India. The Transfer Pricing Officer (hereinafter “TPO”) found the revenue pertaining to AE segment quite significant while comparing

Assistant Commissioner of Income Tax, Circle-6(1)(1), Bangalore vs. Sony India Software Centre Pvt Ltd, Bellandur, Bangalore

ITA 1550/BANG/2024[2017-18]Status: DisposedITAT Bangalore13 Dec 2024AY 2017-18

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadavassessment Year : 2017-18

For Appellant: Shri Narendra Kumar Jain, AdvocateFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 195Section 28Section 40a

wherein the following two additions were made. a) Addition of Rs. 1,44,73,422/- on account goods received free of cost from its Associated Enterprises b) Disallowance of Rs. 9,59,334/- being payments of training charges paid to a Non Resident individual on which tax at sources

Je Energy Ventures P.Ltd, Noida vs. ACIT, Circle-5(1)(1), G B Nagar

ITA 1450/DEL/2022[2018-19]Status: DisposedITAT Delhi13 Dec 2024AY 2018-19

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaassessment Year: 2018-19 Je Energy Ventures P. Ltd., Vs Acit, Plot No.1A, Sector-16A, Circle 5(1)(1), Industrial Area, Gb Nagar. Noida (Uttar Pradesh) – 201 301. Pan : Aaace0653L

For Appellant: Shri K.M. Gupta, Advocate &For Respondent: Shri Zafarul Haque Tanveer, CIT-DR

Section 143(3)Section 92A

assessee and the EXIM Bank only, which are unrelated parties. The vital constituent of an international transaction is that the same should be between associated enterprises. However, Section 92B(2) of the Act outlines the circumstances under which a transaction between two persons would be deemed to be between ... associated enterprises. 5 9. What is important is to be examined now is if for the purpose of section 92B(2) of the Act, the assessee’s transaction with EXIM Bank is an independent transaction or a prior agreement between the assessee and its AE, makes the assessee’s transaction

Deputy Commissioner of Income -Tax, Ahmedabad vs. Priya Blue Recycling LLP, Gujarat

In the result, the appeal of the Department is dismissed

ITA 641/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad11 Dec 2024AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Sanjay Kumar, Sr. DRFor Respondent: Shri Tushar Hemani, Sr. Adv. & Shri

Section 132Section 271ASection 40A(2)(b)Section 92CSection 92D

consideration, the penalty was initiated for non-maintenance of documents on an incorrect assumption of fact that the assessee had international transaction with an Associated Enterprise. However, while passing the order, Ld. CIT(A) has correctly taken note of the fact that the assessee did not have any international transactions ... only transactions with a domestic associated enterprise. On perusal of the Tax Audit Report (at page 11 of the Paper Book at Column 23) and also the relevant extract of purchase ledger, submitted by the assessee before the TPO, it is observed that the assessee had made purchases from Priya

Orchid Pharma Limited, Chennai vs. DCIT, Chennai

In the result, the appeal of the assessee is partly allowed

ITA 73/CHNY/2017[2012-13]Status: DisposedITAT Chennai11 Dec 2024AY 2012-13

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./ Ita No.73/Chny/2017 निर्ाारण वर्ा /Assessment Years: 2012-13

For Appellant: Shri B.Ramakrishnan, FCA & ShriFor Respondent: Shri A.Sasikumar, CIT

Section 143(3)Section 92A(2)(i)

view of the matter, as also bearing in mind the earlier discussions on the issue, the assessee and Northstar can not be treated as 'associated enterprises' under section 92 A. We uphold the plea of the assessee. 18. Ground no. 2 is thus allowed….” :- 4 -: 3.3 The facts of present

Humboldt Wedag India Pvt. Ltd, New Delhi vs. Additional/Joint/ Deputy/ACIT, Circle-10(1), Delhi

The appeal of the assessee is allowed

ITA 3074/DEL/2024[2020-21]Status: DisposedITAT Delhi10 Dec 2024AY 2020-21

Bench: Shri Pradip Kumar Kedia & Shri Anubhav Sharmaassessment Year: 2020-21 Humboldt Wedag India Pvt. Ltd., Vs Addl. Cit, A-36, Mehtab House, Circle-10(1), Mohan Co-Op. Estate, Delhi. Mathura Road, Delhi – 110 044. Pan: Aaach7474G (Appellant) (Respondent) Assessee By : Shri Siddhesh Chaugule, Ca & Ms Hemlata Sharma, Ca Revenue By : Shri Dharm Veer Singh, Cit-Dr Date Of Hearing : 20.11.2024 Date Of Pronouncement : .12.2024 Order Per Anubhav Sharma, Jm:

For Appellant: Shri Siddhesh Chaugule, CA &For Respondent: Shri Dharm Veer Singh, CIT-DR

Section 143(3)

manufacturing and supply of equipment plants & machinery for cement manufacturing companies. During FY 2019-20, the Appellant entered into various international transactions with its associated enterprises (‘AEs’). All other international transactions of the Appellant have been accepted to be at arm’s length and no adverse inference has been drawn

Robert Bosch Engineering and Business Solutions Private Limited, Bengaluru vs. The Joint Commissioner of Income Tax, Large Tax Payers Unit, Bangalore

In the result, the appeal of the Revenue is hereby dismissed

ITA 593/BANG/2020[2012-13]Status: DisposedITAT Bangalore09 Dec 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sridhar E, CIT (DR)For Respondent: Date of hearing

Section 115Section 115JSection 237Section 80J

learned CIT-A erred in considering certain comparables while calculating the ALP of the international transaction carried out by the assessee with its associated enterprise. 37. The necessary facts are that the assessee company, during the year, is engaged in various types of international transactions with associated enterprises. For transfer ... companies with a turnover exceeding ₹200 crores as comparables while calculating the ALP for the international transactions carried out by the assessee with its Associated Enterprise (AE). According to the assessee, the list of companies with a turnover exceeding ₹200 crores is as follows: (i) Infosys BPO Limited

Deputy Commissioner of Income Tax, Circle- 2, Ltu, Bengaluru vs. M/S. Robert Bosch Engineering and Business Solutions Private Limited, Bangalore

In the result, the appeal of the Revenue is hereby dismissed

ITA 446/BANG/2020[2012-13]Status: DisposedITAT Bangalore09 Dec 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sridhar E, CIT (DR)For Respondent: Date of hearing

Section 115Section 115JSection 237Section 80J

Goldman Sachs (India) Securiteis Private Limited, Mumbai vs. Add/Jt/Dy/Asst/CIT/ITO/NFAC, Delhi

ITA 763/MUM/2022[2017-18]Status: DisposedITAT Mumbai09 Dec 2024AY 2017-18

Bench: Shri Amarjit Singhshri Sandeep Singh Karhail

For Appellant: Shri Madhur AgrawalFor Respondent: Ms. Neena Jeph, CIT-DR

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 253(1)Section 92C

Price (ALP) of the international transaction pertaining to provision of non-binding investment advisory and support services (IA services) by the Appellant to its associated enterprises (AEs), inter alia, on following grounds: a) Rejecting the transfer pricing documentation maintained by the Appellant in accordance with provisions of the Act read ... Length Price (ALP) of the international transaction pertaining to provision of Information Technology enabled Services (ITeS) by the Appellant to its associated enterprises (AEs), inter alia, on following grounds: a) Rejecting the transfer pricing documentation maintained by the Appellant in accordance with provisions of the Act read with the Rules

K.G. Denim Limited, Coimbatore vs. DCIT, Tp-2(1), Chennai

In the result, appeal filed by the assessee is allowed

ITA 1718/CHNY/2024[2020-21]Status: DisposedITAT Chennai05 Dec 2024AY 2020-21

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1718/Chny/2024 िनधा"रण वष" / Assessment Year: 2020-21 K G Denim Limited, Dcit, 1, Thenthirumalai, V. Tp-2(1), Jadayampalayam B.O., Chennai. Dhoddabavi, Coimbatore – 641 302. [Pan: Aaack-7940-C] (अपीलाथ"/Assessee) (""यथ"/Respondent) अपीलाथ" क" ओर से/Assessee By : Shri. Arjun Raj, Advocate : Shri. A. Sasikumar, Cit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 11.09.2024 घोषणा क" तारीख/Date Of Pronouncement : 05.12.2024

For Appellant: Shri. Arjun Raj, Advocate

Section 263Section 263(1)(c)Section 801A

directing the Transfer Pricing Officer to recompute the ALP of the revenue of the eligible unit from sale of power to its associated enterprises being the power consuming unit of the Assessee and its sister concern Sri Kannapiran Mills Limited. 6. The ld.AR for the assessee objected to the assumption ... market under long-term contracts and adopting the same for computing the revenue of the eligible unit from sale of power to its associated enterprises being the power consuming unit of the Assessee and its sister concern Sri Kannapiran Mills. The downward adjustment to the extent of difference between

Concur Technologies (India) Private Limited, Bengaluru vs. Assistant Commissioner F Income Tax Circle 2(2)(1), Bengaluru

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1925/BANG/2024[2020-2021]Status: DisposedITAT Bangalore05 Dec 2024AY 2020-2021

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Chavali Narayan, CAFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144C(5)Section 92B

relating to transfer pricing ("TP") matter 2. The learned AO/ TPO erred in law and facts by re- characterizing the outstanding receivables from the associated enterprise (AEs) as loan extended to the AE and thereby erred in computing notional interest on the outstanding balance from the AE amounting ... brief facts of the case show that the assessee, Concur Technologies (India) Private Limited, is engaged in the provision of services to its Associated Enterprises (AEs) of IT-enabled Services [ITes] with respect to travel request, travel bookings and claims of expenses. The assessee filed its return of income

Otis Elevator Company (India) Limited, Mumbai vs. DCIT, 13(1)(2), Mumbai

ITA 3337/MUM/2024[2020-21]Status: DisposedITAT Mumbai29 Nov 2024AY 2020-21

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Sunil Kumar Singh, Hon'Bleι.Τ.Α. No. 3337/Mum/2024

For Appellant: Shri Rajan Vora & Nikhil Tiwari, A/RsFor Respondent: Shri Asif Karmali, Sr. D/R

Section 143(3)Section 144C(13)Section 234ASection 234CSection 234FSection 270A(1)Section 37(1)Section 92CSection 92C(3)

Length Price ('ALP') of international transaction of Payment of Management fee under an inter- company service agreement entered into with its Associated Enterprise ('AE') i.e., M/s. Otis International Asia Pacific Pte. Ltd as NIL; Disregarding the benchmarking and economic analysis without cogent reasons: 3. erred in not accepting the economic

DCIT, Circle-4(2), Delhi vs. Boeing India Private Limited, Delhi

In the result, appeal by the Revenue is dismissed

ITA 1838/DEL/2024[2019-20]Status: DisposedITAT Delhi28 Nov 2024AY 2019-20

Bench: Shri Shamim Yahya & Shri Sudhir Pareeka.Yr. : 2019-20 Dcit, Circle 4(2), Boeing India Private Limited, Room No. 384, 3Rd Floor, 3Rd Floor, Dlf Centre, Vs. C.R. Building, Sansad Marg, New Delhi – 2 New Delhi – 1 (Pan:- Aahcb1218P) (Appellant) (Respondent) Appellant By : Sh. Kshitij Bansal, Ca Respondent By : Sh. Rajesh Kumar Dhanesta, Sr. Dr. Date Of Hearing : 25.11.2024 Date Of Pronouncement : 28.11.2024 Order

For Appellant: Sh. Kshitij Bansal, CAFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr. DR

Section 139(1)Section 143Section 143(1)Section 36(1)(va)Section 40A(7)

incorporated on 9.3.2017 under the provisions of Companies Act, 2013. During financial year 2018-19, the assesee was engaged in various services to its Associated Enterprises (AEs) on cost plus basis. The assessee filed its return of income for AY 2019-20 on 29.11.2019 declaring a total income

Income Tax Officer Ward 2(1)(1) Intl.Taxation, Delhi vs. Hcl Technologies Limited, New Delhi

In the result, appeal is partly allowed

ITA 1392/DEL/2024[2012-13]Status: DisposedITAT Delhi28 Nov 2024AY 2012-13

Bench: Ms Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Neeraj Jain, AdvFor Respondent: Ms. Surbhi Sharma, CIT-DR

Section 10ASection 201Section 201(1)Section 9(1)(vii)

Others vs. Asst. CIT Circle International Taxation 2(1) (1) New Delhi, in ITA No. 537/Del/2021)holding the income paid to foreign associated enterprises / group companies of the Assessee as not chargeable in India the Assessee was not liable to deduct tax at source from such payments. The levy

Schaeffler India Limited, Vadodara, Gujarat vs. Assistant Director of Income Tax, CPC, Bangalore (Jao-Deputy Commissioner of Income Tax Circle1(1)(1), Vadodara, Gujarat

ITA 692/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad27 Nov 2024AY 2019-20

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Shri Prathvi Raj Meena, CIT D.R. & Smt

Section 143(3)Section 144CSection 234Section 271(1)(c)Section 37

issue. 10. The brief facts / background relating to this issue is that the assessee company had paid management fees to Schaeffler Holding China Company (“Associated Enterprise”) and bench-marked the transaction by using TNMM. The Transfer Pricing Officer determined ALP of the transaction at Rs. NIL by treating the services ... performed by the Associated Enterprise at stewardship / shareholder activity. In appeal, the assessee provided details regarding the nature of services, service level agreement, break-up of amount paid for services, relevant invoices and email communications in support of services rendered by the AE to the assessee company

The ACIT, Circle-1(1)(1), Vadodara vs. Schaeffler India Ltd.( Erstwhile Luk India Pvt. Ltd)), Vadodara

ITA 299/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad27 Nov 2024AY 2012-13

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Shri Prathvi Raj Meena, CIT D.R. & Smt

Section 143(3)Section 144CSection 234Section 271(1)(c)Section 37

Schaeffler India Ltd.(A Successor of Luk India Pvt. Ltd)), Vadodara vs. The ACIT, Circle-1(1)(1) (Earlier ACIT, Circle-1, Hosur), Vadodara

ITA 275/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad27 Nov 2024AY 2012-13

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Shri Prathvi Raj Meena, CIT D.R. & Smt

Section 143(3)Section 144CSection 234Section 271(1)(c)Section 37

Newgen Imaging Systems Pvt. Ltd., Chennai vs. DCIT, International Taxation-2(2), Chennai

In the result the grounds of appeal raised by the assesse is allowed

ITA 1626/CHNY/2024[2010-11]Status: DisposedITAT Chennai27 Nov 2024AY 2010-11

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1626/Chny/2024 निर्धारण वर्ा /Assessment Years: 2010-11 Newgen Imaging Systems Private Deputy Commissioner Of Income Limited, International Taxation-2(2), No.268, Royapettah High Road, Chennai. Royapettah, Madras, Tamil Nadu-600014. [Pan: Aaacn2041B] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri G. Shiva Kumar, Advocate अपीलार्थी की ओर से/ Assessee By : Shri Keerthi Narayanan, Jcit प्रत्यर्थी की ओर से /Revenue By सुनवाई की तारीख/Date Of Hearing : 02.09.2024 घोषणा की तारीख /Date Of Pronouncement : 27.11.2024

For Appellant: Shri Keerthi Narayanan, JCIT

Section 201(1)Section 250Section 40Section 9(1)

main issue is as regards to the treatment of payment for purchase of the off-the-shelf software products and as to whether the Associated Enterprises of the Assessee provides this directly to the Assessee or through another entity is not material. The Assessee has received certain software products ... contended that the above said expenses were negotiated and incurred at a group level with the third-party vendors by the overseas Associated Enterprises [AE] on behalf of all the group entities and the corresponding cost was recharged to the various entities on a cost-to-cost basis without

Shri Venkateshwara Panmasala Industries Pvt Ltd, Kolhapur vs. ACIT, Central Circle-1(1), Kolhapur

The appeal stands partly allowed for statistical purposes

ITA 733/PUN/2024[2019-20]Status: DisposedITAT Pune26 Nov 2024AY 2019-20

Bench: Hon’Ble Shri G. D. Padmahshali & Hon’Ble Shri Vinay Bhamoreassessment Year : 2019-20 Shri Venkateshwara Panmasala Industries Pvt Ltd, 335, Sangli Kolhapur Byepass Road, Dharangutti Via Jaysingpur – 416 203. Pan: Aaccs5553P. . . . . . . . Appellant V/S The Asstt Commissioner Of Income Tax, Central Circle-1(1), Kolhapur . . . . . . . Respondent Appearances Assessee By : Mr Hari Krishan [‘Ld. Ar’] Revenue By : Mr Arvind Desai [‘Ld. Dr’] Date Of Conclusive Hearing : 25/09/2024 Date Of Pronouncement : 26/11/2024 Order Per G. D. Padmahshali, Am; The Present Appeal Of The Assessee Is Instituted U/S 253(1) Of The Income Tax Act, 1961 [‘The Act’ Hereinafter] Which Impugns First Appellate Order Dt. 06/03/2024 Passed By National Faceless Appeal Centre, Delhi [‘Ld. Cit(A)/ Ld. Nfac’ Hereinafter] U/S 250 Of The Act Which Emerged In Relation To & Out Of Assessment Order Dt. 24/11/2023 Passed By Ld. Assessment Unit, Nfac [‘Ld. Ao’ Hereinafter] U/S 147 R.W.S 144B Of The Act For Assessment Year 2019-20 [‘Ay’ Hereinafter].

For Appellant: Mr Hari Krishan [‘Ld. AR’]For Respondent: Mr Arvind Desai [‘Ld. DR’]

Section 132Section 132(4)Section 143(1)Section 147Section 148ASection 250Section 253(1)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL, ‘B’ BENCH PUNE BEFORE HON’BLE SHRI G. D. PADMAHSHALI, ACCOUNTANT MEMBER AND HON

Deputy Commissioner of Income-Tax, Circle - 5, Pune vs. Renishaw Metrology Systems Ltd, Pune

The appeal of the Revenue is partly allowed for statistical purposes in above terms

ITA 628/PUN/2021[2013-14]Status: DisposedITAT Pune26 Nov 2024AY 2013-14

Bench: Hon’Ble Smt Astha Chandra, Judical Member & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No. 0628/Pun/2021 िनधा"रण वष" / Assessment Year : 2013-14 Dy. Commissioner Of Income Tax, Central Circle-5, Pune . . . . . . . अपीलाथ" / Appellant

For Appellant: Mr Ajit Jain [‘Ld. AR’]For Respondent: Mr Manish Mehta [‘Ld. DR’]

Section 143(2)Section 143(3)Section 246A(1)Section 250Section 253(2)Section 92C

Renishaw International Ltd. United Kingdom. The assessee company engaged in the business of (a) manufacturing of Arms & Cables, (b) software development services for its associated enterprises [in short ‘AEs’] (c) marketing support service of group product line and (d) trading of group product. 1.2 The original of return of income