https://www.taxtmi.com/caselaws?id=207064 Royalty paid to an associated enterprise could not be treated as nil ALP merely by questioning commercial expediency or business benefit; the transfer pricing adjustment was set aside and remanded for fresh examination of arm's length price and trademark-related facts. Disallowance of usance interest and staff welfare expenses was also set aside because the business discretion and expense claims required proper documentary verification and specific factual scrutiny, not broad conjecture or ad hoc disallowance. Interest under section 234B was remanded as consequential to the reassessment. The challenge to initiation of penalty proceedings under section 271(1)(c) was rejected because mere initiation caused no present prejudice. en-us Thu, 08 Sep 2011 00:00:00 +0530 Mon, 02 May 2016 15:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207064 Royalty paid to an associated enterprise could not be treated as nil ALP merely by questioning commercial expediency or business benefit; the transfer pricing adjustment was set aside and remanded for fresh examination of arm's length price and trademark-related facts. Disallowance of usance interest and staff welfare expenses was also set aside because the business discretion and expense claims required proper documentary verification and specific factual scrutiny, not broad conjecture or ad hoc disallowance. Interest under section 234B was remanded as consequential to the reassessment. The challenge to initiation of penalty proceedings under section 271(1)(c) was rejected because mere initiation caused no present prejudice. Case-Laws Income Tax Thu, 08 Sep 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207064