https://www.taxtmi.com/caselaws?id=784436 Incentive payments to employees were held to be additional remuneration in the nature of bonus/incentive (not severance), and, being covered by s. 43B(c), were deductible since paid before the return-filing due date; the disallowance was deleted. On TP comparables for an ITES provider, a high-end KPO was excluded for functional dissimilarity and different risk/scale profile, while certain ITES/BPO comparables were included applying functional comparability, availability of segmental data, and consistency with earlier years; the comparable set was accordingly revised. For s. 10AA, reallocation of common expenses without corresponding revenue adjustment under a cost-plus model, and without rejecting books u/s 145, was held to produce artificial unit results; the restriction treated as "addition" was deleted. en-us Wed, 31 Dec 2025 00:00:00 +0530 Mon, 05 Jan 2026 08:04:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784436 Incentive payments to employees were held to be additional remuneration in the nature of bonus/incentive (not severance), and, being covered by s. 43B(c), were deductible since paid before the return-filing due date; the disallowance was deleted. On TP comparables for an ITES provider, a high-end KPO was excluded for functional dissimilarity and different risk/scale profile, while certain ITES/BPO comparables were included applying functional comparability, availability of segmental data, and consistency with earlier years; the comparable set was accordingly revised. For s. 10AA, reallocation of common expenses without corresponding revenue adjustment under a cost-plus model, and without rejecting books u/s 145, was held to produce artificial unit results; the restriction treated as "addition" was deleted. Case-Laws Income Tax Wed, 31 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784436