https://www.taxtmi.com/caselaws?id=248031 Segmental results for the contract manufacturing activity were available and had been accepted in earlier years, so an entity-level comparison for transfer pricing was not appropriate; the arm's length adjustment was therefore deleted. The provision for discount was treated as a contingent and unascertained liability and was disallowed, though the reversed excess provision was left open for verification and possible allowance if already disallowed in an earlier year. Foreign currency travel expenses for training and marketing/business promotion were required to be excluded from both export turnover and total turnover for section 10B relief. en-us Fri, 21 Mar 2014 00:00:00 +0530 Fri, 30 May 2014 11:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=248031 Segmental results for the contract manufacturing activity were available and had been accepted in earlier years, so an entity-level comparison for transfer pricing was not appropriate; the arm's length adjustment was therefore deleted. The provision for discount was treated as a contingent and unascertained liability and was disallowed, though the reversed excess provision was left open for verification and possible allowance if already disallowed in an earlier year. Foreign currency travel expenses for training and marketing/business promotion were required to be excluded from both export turnover and total turnover for section 10B relief. Case-Laws Income Tax Fri, 21 Mar 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=248031