https://www.taxtmi.com/caselaws?id=338950 Transfer pricing adjustment for advertisement, marketing and sales promotion expenses was unsustainable because the Revenue had not established an international transaction with an identifiable price, and bright line reasoning could not create one. The notional interest adjustment on delayed receivables was also deleted because the main international transactions had already been benchmarked under TNMM, leaving no separate sustainable basis for an independent arm's length adjustment. Deduction under section 10A was allowed for unit II because the record supported its export-oriented data processing and IT-enabled services activity, and the contrary business characterization did not displace the factual finding of eligibility. en-us Wed, 21 Sep 2016 00:00:00 +0530 Tue, 26 May 2026 15:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=338950 Transfer pricing adjustment for advertisement, marketing and sales promotion expenses was unsustainable because the Revenue had not established an international transaction with an identifiable price, and bright line reasoning could not create one. The notional interest adjustment on delayed receivables was also deleted because the main international transactions had already been benchmarked under TNMM, leaving no separate sustainable basis for an independent arm's length adjustment. Deduction under section 10A was allowed for unit II because the record supported its export-oriented data processing and IT-enabled services activity, and the contrary business characterization did not displace the factual finding of eligibility. Case-Laws Income Tax Wed, 21 Sep 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=338950