https://www.taxtmi.com/caselaws?id=247142 Transfer pricing adjustments for cost allocation and cost recharges from associated enterprises were found to require fuller examination of invoices, allocation keys, service evidence, benefit test and benchmarking material; the matter was remanded for de novo adjudication. Consultancy expenditure on feasibility and viability studies for a proposed new unit also required fresh factual inquiry to determine whether it was revenue or capital in nature, including whether the project created a new asset, was abandoned, or was merely an expansion of existing business; the disallowance was set aside and restored for fresh decision. The penalty-related ground was not substantively adjudicated. en-us Wed, 18 Dec 2013 00:00:00 +0530 Sat, 03 May 2014 09:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=247142 Transfer pricing adjustments for cost allocation and cost recharges from associated enterprises were found to require fuller examination of invoices, allocation keys, service evidence, benefit test and benchmarking material; the matter was remanded for de novo adjudication. Consultancy expenditure on feasibility and viability studies for a proposed new unit also required fresh factual inquiry to determine whether it was revenue or capital in nature, including whether the project created a new asset, was abandoned, or was merely an expansion of existing business; the disallowance was set aside and restored for fresh decision. The penalty-related ground was not substantively adjudicated. Case-Laws Income Tax Wed, 18 Dec 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=247142