https://www.taxtmi.com/caselaws?id=204665 Transfer pricing for royalty must be tested against materially comparable contractual terms and commercial circumstances; a mere difference in royalty rate is insufficient where the licence period and product coverage differ, so the royalty adjustment was not sustainable. Research and development cess on royalty, payable by the industrial concern importing technology under the relevant cess law, could not be shifted into the arm's length price computation, so that addition was rejected. Interest earned on employee loans in the ordinary course of business was treated as business income for computing the section 80HHC deduction, so the assessee's deduction claim was to be recomputed on that basis. en-us Thu, 30 Jul 2009 00:00:00 +0530 Fri, 29 Jul 2011 22:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=204665 Transfer pricing for royalty must be tested against materially comparable contractual terms and commercial circumstances; a mere difference in royalty rate is insufficient where the licence period and product coverage differ, so the royalty adjustment was not sustainable. Research and development cess on royalty, payable by the industrial concern importing technology under the relevant cess law, could not be shifted into the arm's length price computation, so that addition was rejected. Interest earned on employee loans in the ordinary course of business was treated as business income for computing the section 80HHC deduction, so the assessee's deduction claim was to be recomputed on that basis. Case-Laws Income Tax Thu, 30 Jul 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=204665