https://www.taxtmi.com/caselaws?id=763398 Assets received free of cost on a returnable basis from associated enterprises were not taxable as a business benefit under section 28(iv) where they were used only temporarily for testing and work, were later re-exported or destroyed, and their depreciation had already been built into the transfer pricing cost base; taxing them again would amount to double taxation. The deletion of the addition was upheld. Training fees paid to a non-resident for workshop and training services were also held not to constitute fees for technical, managerial, or consultancy services on the facts found, so tax deduction at source was not established and the disallowance under section 40(a)(i) failed. The deletions were sustained in favour of the assessee. en-us Fri, 13 Dec 2024 00:00:00 +0530 Wed, 18 Dec 2024 09:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763398 Assets received free of cost on a returnable basis from associated enterprises were not taxable as a business benefit under section 28(iv) where they were used only temporarily for testing and work, were later re-exported or destroyed, and their depreciation had already been built into the transfer pricing cost base; taxing them again would amount to double taxation. The deletion of the addition was upheld. Training fees paid to a non-resident for workshop and training services were also held not to constitute fees for technical, managerial, or consultancy services on the facts found, so tax deduction at source was not established and the disallowance under section 40(a)(i) failed. The deletions were sustained in favour of the assessee. Case-Laws Income Tax Fri, 13 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763398