Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Weighted deduction for scientific research expenditure was allowed on regular remuneration paid to the Chief Scientific Officer, as it was incurred for day-to-day research services, but the one-time performance bonus linked to patent licensing success was excluded as not directly related to research activity. ESOP expenditure disallowance was deleted by following the Tribunal's earlier orders in the assessee's own case. Weighted deduction under section 35(2AB) was confined to expenditure verified and certified by DSIR in Form 3CL, so the balance manpower and travel claim was not extended the deduction. For the alternative claim, deduction under section 37(1) was permitted subject to verification that the same amount had not already been claimed in the profit and loss account.
Weighted deduction for scientific research expenditure was allowed on regular remuneration paid to the Chief Scientific Officer, as it was incurred for day-to-day research services, but the one-time performance bonus linked to patent licensing success was excluded as not directly related to research activity. ESOP expenditure disallowance was deleted by following the Tribunal's earlier orders in the assessee's own case. Weighted deduction under section 35(2AB) was confined to expenditure verified and certified by DSIR in Form 3CL, so the balance manpower and travel claim was not extended the deduction. For the alternative claim, deduction under section 37(1) was permitted subject to verification that the same amount had not already been claimed in the profit and loss account.
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