https://www.taxtmi.com/caselaws?id=331437 Expenditure incurred before a foreign subsidiary came into existence, where the activity was undertaken only in the capacity of a shareholder, was treated as outside transfer pricing and no mark-up was permitted on its reimbursement. By contrast, post-incorporation managerial services to the subsidiary were regarded as a separate international transaction and the adjustment on that reimbursement was sustained. The employee stock option plan expenditure issue was not finally decided on merits and was remitted to the Assessing Officer for verification and fresh adjudication in light of the applicable precedent. en-us Wed, 17 Aug 2016 00:00:00 +0530 Tue, 23 Aug 2016 14:39:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=331437 Expenditure incurred before a foreign subsidiary came into existence, where the activity was undertaken only in the capacity of a shareholder, was treated as outside transfer pricing and no mark-up was permitted on its reimbursement. By contrast, post-incorporation managerial services to the subsidiary were regarded as a separate international transaction and the adjustment on that reimbursement was sustained. The employee stock option plan expenditure issue was not finally decided on merits and was remitted to the Assessing Officer for verification and fresh adjudication in light of the applicable precedent. Case-Laws Income Tax Wed, 17 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=331437