Transfer-pricing rules treat entities as associated enterprises...

Transfer-pricing rules treat entities as associated enterprises where the statutory voting-power condition is met through common shareholding in a counterparty's parent, including wholly owned step-down subsidiaries. Chapter X operates as a valuation mechanism and requires arm's length pricing through a prescribed most appropriate method. Scientific-research capital expenditure requires a nexus with the taxpayer's own business; research undertaken for group entities may not qualify. Software with multi-year, indeterminate use is capital expenditure, whereas annual-validity software is revenue expenditure. Unpaid leave-encashment provisions are deductible only on a payment basis. Research expenditure depends on intended long-term benefit and may require factual segregation where royalties or lease income arise.