https://www.taxtmi.com/caselaws?id=783960 Reimbursement of third-party marketing event expenses routed through the assessee for convenience was held not to constitute an international transaction, since mere facilitation of payments involved no service or value addition; the TPO's mark-up based on event-organiser comparables was unsustainable, and the TP adjustment was deleted. Year-end provisions (other than ad hoc) were held deductible if relating to the relevant AY and reversed in the immediately succeeding year, with no TDS consequence where payees' accounts were not credited; however, allowability of provision for installation/authorised services (warranty-like) depended on being created on a scientific basis under SC law, so the matter was remanded to the AO for verification, with relief allowed in principle. Book profit under s.115JB and interest were directed to be recomputed/verified by the AO in accordance with law. en-us Mon, 01 Dec 2025 00:00:00 +0530 Fri, 26 Dec 2025 07:18:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783960 Reimbursement of third-party marketing event expenses routed through the assessee for convenience was held not to constitute an international transaction, since mere facilitation of payments involved no service or value addition; the TPO's mark-up based on event-organiser comparables was unsustainable, and the TP adjustment was deleted. Year-end provisions (other than ad hoc) were held deductible if relating to the relevant AY and reversed in the immediately succeeding year, with no TDS consequence where payees' accounts were not credited; however, allowability of provision for installation/authorised services (warranty-like) depended on being created on a scientific basis under SC law, so the matter was remanded to the AO for verification, with relief allowed in principle. Book profit under s.115JB and interest were directed to be recomputed/verified by the AO in accordance with law. Case-Laws Income Tax Mon, 01 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783960