https://www.taxtmi.com/caselaws?id=784374 ITAT Mumbai applied earlier years' rulings to delete major transfer pricing additions on software, technical and consultancy services, upheld a 0.5% guarantee commission benchmark, and rejected a notional brand royalty adjustment. It also held that foreign state taxes in the USA may be deductible subject to treaty verification, imported software and non-resident agent commission were not subject to withholding tax on the facts, and section 14A disallowance failed for want of recorded dissatisfaction. The Tribunal further allowed brand building and brand equity subscription as revenue , subscription fees as payments for copyrighted articles, year-end accrued provisions, CSR-linked donations under section 80G, gratuity through OCI, interest income deduction under section 10AA, and tax sparing credit on Singapore dividend income. en-us Tue, 30 Dec 2025 00:00:00 +0530 Fri, 02 Jan 2026 15:17:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784374 ITAT Mumbai applied earlier years' rulings to delete major transfer pricing additions on software, technical and consultancy services, upheld a 0.5% guarantee commission benchmark, and rejected a notional brand royalty adjustment. It also held that foreign state taxes in the USA may be deductible subject to treaty verification, imported software and non-resident agent commission were not subject to withholding tax on the facts, and section 14A disallowance failed for want of recorded dissatisfaction. The Tribunal further allowed brand building and brand equity subscription as revenue , subscription fees as payments for copyrighted articles, year-end accrued provisions, CSR-linked donations under section 80G, gratuity through OCI, interest income deduction under section 10AA, and tax sparing credit on Singapore dividend income. Case-Laws Income Tax Tue, 30 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784374