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    <title>2019 (7) TMI 660 - ITAT PUNE</title>
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    <description>Expenditure on expat technicians for installation and commissioning of new equipment was treated as capital-linked and excluded from operating expenses for transfer pricing purposes, with operating profit to be recomputed accordingly. Management incentive bonus under a separate employee reward scheme was held to be business expenditure and allowable under section 37(1). A warranty provision made on a scientific and consistently followed basis was allowed as a deductible claim. Transfer pricing adjustment was confined to international transactions, while product development and testing payments required fresh verification. Foreign exchange loss from trading transactions and compensation income were treated as operating items, and retention bonus was allowed as revenue expenditure.</description>
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