https://www.taxtmi.com/caselaws?id=212657 HC upheld the Tribunal's deletion of the TPO's disallowance of brand fee/royalty payments, ruling the TPO was incorrect to deny ALP adjustment solely because the assessee incurred continuous losses. The court accepted OECD guidelines as a valid input, held that business expenditure need only be incurred wholly and exclusively for business (not shown to generate immediate profit), and found the assessee furnished ample factual justification-employee costs, finance charges, administrative expenses, depreciation and capacity increases-to explain sustained losses. Decision rendered against the revenue. en-us Thu, 29 Mar 2012 00:00:00 +0530 Mon, 27 Jul 2026 13:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=212657 HC upheld the Tribunal's deletion of the TPO's disallowance of brand fee/royalty payments, ruling the TPO was incorrect to deny ALP adjustment solely because the assessee incurred continuous losses. The court accepted OECD guidelines as a valid input, held that business expenditure need only be incurred wholly and exclusively for business (not shown to generate immediate profit), and found the assessee furnished ample factual justification-employee costs, finance charges, administrative expenses, depreciation and capacity increases-to explain sustained losses. Decision rendered against the revenue. Case-Laws Income Tax Thu, 29 Mar 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=212657