https://www.taxtmi.com/caselaws?id=287165 Transfer pricing treatment turned on the real character of the transactions: share application money to a wholly owned foreign subsidiary and optionally fully convertible debentures were held to retain capital character, so notional interest adjustments were deleted. For Pantoprazole sales, TNMM was accepted over Profit Split Method because the assessee functioned as a contract manufacturer while the associated enterprise owned the key intangibles and entrepreneurial risks. The ruling also addressed weighted deduction for research-related expenditure, book-profit computation under section 115JB, exclusion of partnership remuneration from book profit, section 14A adjustments, capital treatment of one repair item, and allowance of deduction for a captive power plant. en-us Fri, 16 Jun 2017 00:00:00 +0530 Thu, 02 Apr 2020 10:53:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=287165 Transfer pricing treatment turned on the real character of the transactions: share application money to a wholly owned foreign subsidiary and optionally fully convertible debentures were held to retain capital character, so notional interest adjustments were deleted. For Pantoprazole sales, TNMM was accepted over Profit Split Method because the assessee functioned as a contract manufacturer while the associated enterprise owned the key intangibles and entrepreneurial risks. The ruling also addressed weighted deduction for research-related expenditure, book-profit computation under section 115JB, exclusion of partnership remuneration from book profit, section 14A adjustments, capital treatment of one repair item, and allowance of deduction for a captive power plant. Case-Laws Income Tax Fri, 16 Jun 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=287165