https://www.taxtmi.com/caselaws?id=768555 Transfer pricing adjustment on technical know-how fees paid to the associated enterprise was deleted because the services were shown to be actually rendered, commercially necessary, and supported by a remuneration structure, with the assessee's margin exceeding comparables. The alternative disallowance under section 37 also failed because the expenditure was established as business-related and commercially justified. Mark-up on recovered expenses was deleted where the recovery was treated as a pass-through reimbursement incurred for administrative convenience, with no independent service element. The assessee obtained partial relief on TDS credit and interest, subject to verification of documents and recomputation in accordance with law. en-us Thu, 27 Feb 2025 00:00:00 +0530 Wed, 09 Apr 2025 07:42:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768555 Transfer pricing adjustment on technical know-how fees paid to the associated enterprise was deleted because the services were shown to be actually rendered, commercially necessary, and supported by a remuneration structure, with the assessee's margin exceeding comparables. The alternative disallowance under section 37 also failed because the expenditure was established as business-related and commercially justified. Mark-up on recovered expenses was deleted where the recovery was treated as a pass-through reimbursement incurred for administrative convenience, with no independent service element. The assessee obtained partial relief on TDS credit and interest, subject to verification of documents and recomputation in accordance with law. Case-Laws Income Tax Thu, 27 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768555