https://www.taxtmi.com/caselaws?id=435992 Deferred revenue expenditure and prepayment charges were treated as allowable business deductions where the assessee consistently amortised them over more than one year and that treatment had earlier been accepted. In transfer pricing, additional evidence could be admitted before the appellate authority when sent to the TPO for comments, and the adjustment failed because the CUP, profit split and alternative approaches were not supported by proper comparability analysis; the TNMM comparison was accepted on the facts. Dividend received from the Sri Lankan subsidiary was held to fall under treaty protection, with section 90(2) giving effect to the India-Sri Lanka treaty over the Act, so the dividend was not taxable in India. en-us Mon, 01 Aug 2022 00:00:00 +0530 Sat, 01 Apr 2023 11:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435992 Deferred revenue expenditure and prepayment charges were treated as allowable business deductions where the assessee consistently amortised them over more than one year and that treatment had earlier been accepted. In transfer pricing, additional evidence could be admitted before the appellate authority when sent to the TPO for comments, and the adjustment failed because the CUP, profit split and alternative approaches were not supported by proper comparability analysis; the TNMM comparison was accepted on the facts. Dividend received from the Sri Lankan subsidiary was held to fall under treaty protection, with section 90(2) giving effect to the India-Sri Lanka treaty over the Act, so the dividend was not taxable in India. Case-Laws Income Tax Mon, 01 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435992