https://www.taxtmi.com/caselaws?id=461953 ITAT Bangalore held E-SOP expenses allowable as revenue expenditure under Section 37(1), following Karnataka HC precedent in Biocon Ltd. The expenses were incurred for employee motivation without changing fixed capital structure. However, matter remitted to AO for TDS verification compliance. Regarding transfer pricing, AMP expenditure deemed not an international transaction absent arrangement between assessee and associated enterprise. AMP covered under Advance Pricing Agreement per combined TNMM approach, following Nissan Motor precedent. TPO adjustment conflicted with APA terms, warranting deletion. Issue remitted to AO/TPO for fresh consideration. en-us Tue, 25 Jun 2024 00:00:00 +0530 Sat, 10 May 2025 23:25:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461953 ITAT Bangalore held E-SOP expenses allowable as revenue expenditure under Section 37(1), following Karnataka HC precedent in Biocon Ltd. The expenses were incurred for employee motivation without changing fixed capital structure. However, matter remitted to AO for TDS verification compliance. Regarding transfer pricing, AMP expenditure deemed not an international transaction absent arrangement between assessee and associated enterprise. AMP covered under Advance Pricing Agreement per combined TNMM approach, following Nissan Motor precedent. TPO adjustment conflicted with APA terms, warranting deletion. Issue remitted to AO/TPO for fresh consideration. Case-Laws Income Tax Tue, 25 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461953