https://www.taxtmi.com/caselaws?id=767699 Pure reimbursement of software and expense costs on a cost-to-cost basis was held not to justify a transfer pricing markup absent evidence of value addition, and the related adjustments were deleted. Corporate guarantee fee adjustment was rejected because the assessee's 0.25% benchmarking based on bank quotation comparables was accepted. For inter-unit transfers, CUP-based benchmarking was preferred over TNMM, while electricity-related transfers were sent back for fresh benchmarking on the proper market value basis. Deduction issues under sections 32AC and 35(2AB) were partly remanded or partly allowed, section 14A disallowance was deleted, goodwill depreciation was allowed, inventory write-off disallowance was sustained, and additional depreciation was remanded. en-us Wed, 19 Mar 2025 00:00:00 +0530 Sat, 22 Mar 2025 08:34:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767699 Pure reimbursement of software and expense costs on a cost-to-cost basis was held not to justify a transfer pricing markup absent evidence of value addition, and the related adjustments were deleted. Corporate guarantee fee adjustment was rejected because the assessee's 0.25% benchmarking based on bank quotation comparables was accepted. For inter-unit transfers, CUP-based benchmarking was preferred over TNMM, while electricity-related transfers were sent back for fresh benchmarking on the proper market value basis. Deduction issues under sections 32AC and 35(2AB) were partly remanded or partly allowed, section 14A disallowance was deleted, goodwill depreciation was allowed, inventory write-off disallowance was sustained, and additional depreciation was remanded. Case-Laws Income Tax Wed, 19 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767699