https://www.taxtmi.com/caselaws?id=331177 HC upheld the Tribunal's factual finding that no transfer-pricing adjustment was warranted for pigment imports, rejecting Revenue's contention because accepting it would impermissibly reduce taxable income; the Tribunal's reliance on customs antidumping findings was unchallenged. Regarding technical knowhow/consultancy fees, the HC agreed the agreement functioned as a retainer and the Assessing Officer's allocation of nil value to unused services was unjustified, while noting failure to apply prescribed TP methods renders the TP position legally unsustainable. Finally, HC held Explanation (baa) to s.80HHC does not apply to revaluation credits, so the assessee retains the s.80HHC deduction without reducing revaluation amounts. en-us Mon, 08 Aug 2016 00:00:00 +0530 Sat, 27 Sep 2025 12:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=331177 HC upheld the Tribunal's factual finding that no transfer-pricing adjustment was warranted for pigment imports, rejecting Revenue's contention because accepting it would impermissibly reduce taxable income; the Tribunal's reliance on customs antidumping findings was unchallenged. Regarding technical knowhow/consultancy fees, the HC agreed the agreement functioned as a retainer and the Assessing Officer's allocation of nil value to unused services was unjustified, while noting failure to apply prescribed TP methods renders the TP position legally unsustainable. Finally, HC held Explanation (baa) to s.80HHC does not apply to revaluation credits, so the assessee retains the s.80HHC deduction without reducing revaluation amounts. Case-Laws Income Tax Mon, 08 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=331177