https://www.taxtmi.com/caselaws?id=279663 Transfer pricing adjustment based on international transactions was restored for fresh adjudication after acceptance of additional evidence and factual verification before the TPO. Ad hoc disallowances from general business expenditure and travelling and conveyance were found excessive and were restricted to 2% for want of proper one-to-one verification. On specific claims, the membership fee disallowance was sustained for lack of business nexus, network form charges were allowed as group reimbursement, part relief was granted on training expenses and rent, and the software charge issue was not pressed. Professional fee, foreign tax credit, and TDS credit were remitted for factual verification under the relevant treaty and accounting framework. en-us Wed, 12 Sep 2018 00:00:00 +0530 Sat, 30 Mar 2019 06:03:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=279663 Transfer pricing adjustment based on international transactions was restored for fresh adjudication after acceptance of additional evidence and factual verification before the TPO. Ad hoc disallowances from general business expenditure and travelling and conveyance were found excessive and were restricted to 2% for want of proper one-to-one verification. On specific claims, the membership fee disallowance was sustained for lack of business nexus, network form charges were allowed as group reimbursement, part relief was granted on training expenses and rent, and the software charge issue was not pressed. Professional fee, foreign tax credit, and TDS credit were remitted for factual verification under the relevant treaty and accounting framework. Case-Laws Income Tax Wed, 12 Sep 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=279663