https://www.taxtmi.com/caselaws?id=310378 The Tribunal allowed the assessee's appeal in part and dismissed the Revenue's appeal. It deleted disallowances under Section 37 for brand royalty, technical know-how, and professional fees, affirming these were business expenses. The Tribunal remanded transfer pricing adjustments on brand royalty and professional fees to the TPO for re-evaluation, emphasizing the actual benefits received. It upheld the deletion of disallowance under Section 14A, citing no exempt income was received, and agreed with the DRP that TDS was not required for overseas commission payments under Section 195. The judgment stressed consistency with prior decisions and higher court rulings. en-us Thu, 02 Sep 2021 00:00:00 +0530 Sat, 21 Oct 2023 07:00:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310378 The Tribunal allowed the assessee's appeal in part and dismissed the Revenue's appeal. It deleted disallowances under Section 37 for brand royalty, technical know-how, and professional fees, affirming these were business expenses. The Tribunal remanded transfer pricing adjustments on brand royalty and professional fees to the TPO for re-evaluation, emphasizing the actual benefits received. It upheld the deletion of disallowance under Section 14A, citing no exempt income was received, and agreed with the DRP that TDS was not required for overseas commission payments under Section 195. The judgment stressed consistency with prior decisions and higher court rulings. Case-Laws Income Tax Thu, 02 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310378