https://www.taxtmi.com/caselaws?id=342223 Passive accretion in a foreign parent's brand value from an assessee's sales under the parent's brand name was treated as a by-product of commercial use, not a separately benchmarkable international transaction, so the brand-related transfer pricing adjustment was deleted. Interest paid to Mauritius resident banks was held not taxable in India where no permanent establishment or attributable Indian income was shown, removing withholding and disallowance exposure. Export incentives under the Focus Market Scheme and Focus Products Scheme were recognised only when the licence and benefit crystallised, not on mere accrual. Foreign exchange loss on ECB borrowings used for indigenous assets was allowable as revenue expenditure. Warranty, guarantee and section 14A disallowances were largely deleted, while one section 43B item was sustained and some depreciation issues were remitted. en-us Thu, 27 Apr 2017 00:00:00 +0530 Tue, 22 Aug 2017 14:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=342223 Passive accretion in a foreign parent's brand value from an assessee's sales under the parent's brand name was treated as a by-product of commercial use, not a separately benchmarkable international transaction, so the brand-related transfer pricing adjustment was deleted. Interest paid to Mauritius resident banks was held not taxable in India where no permanent establishment or attributable Indian income was shown, removing withholding and disallowance exposure. Export incentives under the Focus Market Scheme and Focus Products Scheme were recognised only when the licence and benefit crystallised, not on mere accrual. Foreign exchange loss on ECB borrowings used for indigenous assets was allowable as revenue expenditure. Warranty, guarantee and section 14A disallowances were largely deleted, while one section 43B item was sustained and some depreciation issues were remitted. Case-Laws Income Tax Thu, 27 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=342223