https://www.taxtmi.com/caselaws?id=195449 Product development expenses incurred for repeated testing, validation and improvement of existing products were treated as revenue expenditure because they did not create a new asset or product and formed part of the regular business process. Transfer pricing adjustment was held to be confined to international transactions with associated enterprises, and margins under TNMM had to be computed on a consistent operating-cost and operating-revenue base for both the assessee and comparables. Unsuitable public sector comparables were excluded, risk adjustment was recognised for a captive service provider, leased line cost allocation based on consistent usage was accepted, and a comparable rejected for lack of public data was to be verified. A warranty provision made on a scientific basis against an existing business liability was allowable as a deduction. en-us Fri, 21 Apr 2017 00:00:00 +0530 Tue, 31 Oct 2017 10:26:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=195449 Product development expenses incurred for repeated testing, validation and improvement of existing products were treated as revenue expenditure because they did not create a new asset or product and formed part of the regular business process. Transfer pricing adjustment was held to be confined to international transactions with associated enterprises, and margins under TNMM had to be computed on a consistent operating-cost and operating-revenue base for both the assessee and comparables. Unsuitable public sector comparables were excluded, risk adjustment was recognised for a captive service provider, leased line cost allocation based on consistent usage was accepted, and a comparable rejected for lack of public data was to be verified. A warranty provision made on a scientific basis against an existing business liability was allowable as a deduction. Case-Laws Income Tax Fri, 21 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=195449