Clubbing of income from gifted property failed where the claim surfaced after reassessment limitation, sustaining capital-gains assessment in spouse's...
Employee stock-option discount qualifies as revenue expenditure, while royalty and service comparables require reliable functional and transactional b...
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Royalty and technical-fee payments to an associated enterprise may be benchmarked by reference to a unilateral advance pricing agreement accepted by CBDT where its methodology is applicable; the payments were benchmarked at 1.9% of net sales rather than reduced to nil. Related-party manufacturing expenditure covered by section 40A(2)(b), once excluded from specified domestic transactions under section 92BA, cannot support a transfer-pricing adjustment. The manufacturing adjustment was therefore deleted, and the appeal was partly allowed.
Royalty and technical-fee payments to an associated enterprise may be benchmarked by reference to a unilateral advance pricing agreement accepted by CBDT where its methodology is applicable; the payments were benchmarked at 1.9% of net sales rather than reduced to nil. Related-party manufacturing expenditure covered by section 40A(2)(b), once excluded from specified domestic transactions under section 92BA, cannot support a transfer-pricing adjustment. The manufacturing adjustment was therefore deleted, and the appeal was partly allowed.
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