https://www.taxtmi.com/caselaws?id=313976 Ad hoc disallowance of corporate cost allocation was held unsustainable where centralized support services were proved, the allocation was proportionate, and no specific defect or non-business use was shown. Warranty provision was treated as allowable because the liability arose from sales, was computed on a scientific and consistent basis, and represented an ascertained business liability capable of reasonable estimation. The nil arm's length price adjustment for corporate support services to associated enterprises was rejected because the assessee produced agreements and contemporaneous evidence of actual services, and transfer pricing analysis cannot disregard genuine intra-group services merely by questioning business necessity. Revenue's appeals failed, and the disputed disallowances and transfer pricing adjustment were deleted. en-us Mon, 15 Oct 2018 00:00:00 +0530 Sat, 11 May 2024 11:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313976 Ad hoc disallowance of corporate cost allocation was held unsustainable where centralized support services were proved, the allocation was proportionate, and no specific defect or non-business use was shown. Warranty provision was treated as allowable because the liability arose from sales, was computed on a scientific and consistent basis, and represented an ascertained business liability capable of reasonable estimation. The nil arm's length price adjustment for corporate support services to associated enterprises was rejected because the assessee produced agreements and contemporaneous evidence of actual services, and transfer pricing analysis cannot disregard genuine intra-group services merely by questioning business necessity. Revenue's appeals failed, and the disputed disallowances and transfer pricing adjustment were deleted. Case-Laws Income Tax Mon, 15 Oct 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313976