https://www.taxtmi.com/caselaws?id=280169 A contractual warranty provision supported by warranty obligations, past experience and consistent accounting treatment was treated as an ascertained liability, so the disallowance was deleted. Payments for technical drawings and designs acquired on a principal-to-principal basis as copyrighted articles were held not to be royalty, so disallowance under section 40(a)(i) was removed. In transfer pricing, adjustment had to be confined to the international transactions, not entity-wide results; a large-scale comparable was rejected and the tolerance range under the proviso to section 92C(2) was applied, so the adjustment was deleted. Depreciation on an asset purchased from an associated enterprise was restored for fresh consideration after completion of earlier-year proceedings. en-us Thu, 03 Jul 2014 00:00:00 +0530 Tue, 23 Apr 2019 21:26:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=280169 A contractual warranty provision supported by warranty obligations, past experience and consistent accounting treatment was treated as an ascertained liability, so the disallowance was deleted. Payments for technical drawings and designs acquired on a principal-to-principal basis as copyrighted articles were held not to be royalty, so disallowance under section 40(a)(i) was removed. In transfer pricing, adjustment had to be confined to the international transactions, not entity-wide results; a large-scale comparable was rejected and the tolerance range under the proviso to section 92C(2) was applied, so the adjustment was deleted. Depreciation on an asset purchased from an associated enterprise was restored for fresh consideration after completion of earlier-year proceedings. Case-Laws Income Tax Thu, 03 Jul 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=280169