https://www.taxtmi.com/caselaws?id=406336 Transfer pricing adjustment for imports must be confined to international transactions with associated enterprises and cannot extend to the entire manufacturing segment. The applicable margin and the +/- 5% tolerance range must be computed on that restricted transaction base, subject to verification. Recurring monthly payments for market research information do not create an enduring capital asset and are allowable as revenue expenditure. The Revenue's appeals were partly allowed on the transfer pricing issue, while the disallowance of market research expenses was deleted; the cross-objections were dismissed as infructuous. en-us Thu, 08 Apr 2021 00:00:00 +0530 Mon, 12 Apr 2021 08:15:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406336 Transfer pricing adjustment for imports must be confined to international transactions with associated enterprises and cannot extend to the entire manufacturing segment. The applicable margin and the +/- 5% tolerance range must be computed on that restricted transaction base, subject to verification. Recurring monthly payments for market research information do not create an enduring capital asset and are allowable as revenue expenditure. The Revenue's appeals were partly allowed on the transfer pricing issue, while the disallowance of market research expenses was deleted; the cross-objections were dismissed as infructuous. Case-Laws Income Tax Thu, 08 Apr 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406336