https://www.taxtmi.com/caselaws?id=782426 Protective addition for alleged excess share premium under section 56(2)(vii)(b) could not survive where the corresponding substantive addition on the same transaction had already been deleted on merits and no independent basis supported the protective disallowance. Transfer pricing adjustment on reimbursement of expenses also failed because the arrangement did not satisfy the statutory trigger for a specified domestic transaction under section 92BA read with section 80IA(10); the expenses were explained and allocated on a project-capacity basis, and the Revenue did not establish the statutory condition of excess profits in an eligible business. Both additions were therefore unsustainable. en-us Tue, 28 Oct 2025 00:00:00 +0530 Thu, 27 Nov 2025 15:01:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782426 Protective addition for alleged excess share premium under section 56(2)(vii)(b) could not survive where the corresponding substantive addition on the same transaction had already been deleted on merits and no independent basis supported the protective disallowance. Transfer pricing adjustment on reimbursement of expenses also failed because the arrangement did not satisfy the statutory trigger for a specified domestic transaction under section 92BA read with section 80IA(10); the expenses were explained and allocated on a project-capacity basis, and the Revenue did not establish the statutory condition of excess profits in an eligible business. Both additions were therefore unsustainable. Case-Laws Income Tax Tue, 28 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782426