https://www.taxtmi.com/caselaws?id=307378 Transfer pricing of management services fees was accepted on a transaction-level analysis where documentation, earlier-year acceptance and later-year consistency supported arm's length pricing. Depreciation on acquired know-how and related intangibles was allowed because know-how, designs, software and business rights were treated as depreciable intangibles, without any requirement of governmental registration. Bona fide provisions for stock obsolescence and warranty were allowed under normal computation as scientifically estimated business liabilities, and actual warranty expenditure was treated as crystallised. For book profit under section 115JB, MSMED interest provision was not added back because it was an ascertainable statutory liability, warranty provision was not added back, but stock obsolescence provision was added back as a provision for diminution in value of assets. en-us Wed, 17 Oct 2018 00:00:00 +0530 Mon, 10 Apr 2023 08:54:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307378 Transfer pricing of management services fees was accepted on a transaction-level analysis where documentation, earlier-year acceptance and later-year consistency supported arm's length pricing. Depreciation on acquired know-how and related intangibles was allowed because know-how, designs, software and business rights were treated as depreciable intangibles, without any requirement of governmental registration. Bona fide provisions for stock obsolescence and warranty were allowed under normal computation as scientifically estimated business liabilities, and actual warranty expenditure was treated as crystallised. For book profit under section 115JB, MSMED interest provision was not added back because it was an ascertainable statutory liability, warranty provision was not added back, but stock obsolescence provision was added back as a provision for diminution in value of assets. Case-Laws Income Tax Wed, 17 Oct 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307378