https://www.taxtmi.com/caselaws?id=280209 Closely linked long-term project transactions may be benchmarked on an aggregated basis where project-wise comparison distorts margins, so the transfer pricing adjustment on contract revenue was deleted. Separate technical service payments under collaboration agreements were not covered by royalty clauses, so an arm's length price of nil was unsustainable and the adjustment was deleted. Technical drawings and designs purchased as copyrighted articles on a principal-to-principal basis did not amount to royalty or trigger tax deduction at source, so the disallowance was removed. A warranty provision supported by past experience and consistent accounting practice was treated as an ascertained liability and allowed as a deduction. en-us Tue, 28 Feb 2017 00:00:00 +0530 Thu, 25 Apr 2019 06:32:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=280209 Closely linked long-term project transactions may be benchmarked on an aggregated basis where project-wise comparison distorts margins, so the transfer pricing adjustment on contract revenue was deleted. Separate technical service payments under collaboration agreements were not covered by royalty clauses, so an arm's length price of nil was unsustainable and the adjustment was deleted. Technical drawings and designs purchased as copyrighted articles on a principal-to-principal basis did not amount to royalty or trigger tax deduction at source, so the disallowance was removed. A warranty provision supported by past experience and consistent accounting practice was treated as an ascertained liability and allowed as a deduction. Case-Laws Income Tax Tue, 28 Feb 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=280209