https://www.taxtmi.com/caselaws?id=433363 TNMM at the entity level was treated as sufficient to reject a separate AMP transfer pricing adjustment, as no distinct international transaction or obligation to incur excess AMP spend for the foreign AE was shown. Royalty ALP was fixed at 4.05%, while Asian Regional Overheads, warranty charges, design and development charges, and the write-off of advance to the AE were largely deleted because the services or business outgoings were accepted under aggregation or as ordinary business expenses. Expatriate salaries were held deductible under section 37(1) on business expediency. Sales tax subsidy was treated as taxable trading receipt, royalty payment was held revenue in nature, and the section 80JJAA deduction restriction was removed as the employment-period amendment was treated as curative. en-us Tue, 16 Aug 2022 00:00:00 +0530 Fri, 27 Jan 2023 20:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433363 TNMM at the entity level was treated as sufficient to reject a separate AMP transfer pricing adjustment, as no distinct international transaction or obligation to incur excess AMP spend for the foreign AE was shown. Royalty ALP was fixed at 4.05%, while Asian Regional Overheads, warranty charges, design and development charges, and the write-off of advance to the AE were largely deleted because the services or business outgoings were accepted under aggregation or as ordinary business expenses. Expatriate salaries were held deductible under section 37(1) on business expediency. Sales tax subsidy was treated as taxable trading receipt, royalty payment was held revenue in nature, and the section 80JJAA deduction restriction was removed as the employment-period amendment was treated as curative. Case-Laws Income Tax Tue, 16 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433363