https://www.taxtmi.com/caselaws?id=122800 Section 92 was held inapplicable to advertisement expenditure borne under a domestic franchise arrangement because the payment did not affect the foreign parent's income; the transfer-pricing addition was deleted. The Tribunal also held that royalty-related expenditure was deductible in the previous year in which tax deducted at source was actually paid, applying the proviso to section 40(a)(i); the fact that the claim was not made in the earlier year did not prevent allowance. The result was deletion of the disallowance and allowance of the deduction in favour of the assessee. en-us Thu, 01 Oct 2009 00:00:00 +0530 Fri, 17 Aug 2012 12:47:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122800 Section 92 was held inapplicable to advertisement expenditure borne under a domestic franchise arrangement because the payment did not affect the foreign parent's income; the transfer-pricing addition was deleted. The Tribunal also held that royalty-related expenditure was deductible in the previous year in which tax deducted at source was actually paid, applying the proviso to section 40(a)(i); the fact that the claim was not made in the earlier year did not prevent allowance. The result was deletion of the disallowance and allowance of the deduction in favour of the assessee. Case-Laws Income Tax Thu, 01 Oct 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122800