https://www.taxtmi.com/caselaws?id=465733 Disallowance of royalty under s. 40A(2)(a) for payment to the holding company for use of a trademark was rejected because, following binding co-ordinate bench precedent on identical facts, the assessee was entitled to deduction for royalty for use of the brand; the deletion of the addition by the CIT(A) was upheld and the Revenue's grounds were dismissed. Transfer pricing adjustment on corporate guarantee was rejected as the CIT(A), applying tribunal jurisprudence, correctly directed benchmarking at 1% and recomputation of ALP; the CIT(A)'s order was affirmed and the Revenue's grounds were dismissed for both AYs. Downward adjustment under s. 80-IA(8) relating to wheeled/banked wind power adjusted against captive consumption was rejected by applying precedent on identical facts; the CIT(A)'s relief was upheld and the Revenue's appeal was dismissed. en-us Wed, 07 May 2025 00:00:00 +0530 Sat, 03 Jan 2026 11:05:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465733 Disallowance of royalty under s. 40A(2)(a) for payment to the holding company for use of a trademark was rejected because, following binding co-ordinate bench precedent on identical facts, the assessee was entitled to deduction for royalty for use of the brand; the deletion of the addition by the CIT(A) was upheld and the Revenue's grounds were dismissed. Transfer pricing adjustment on corporate guarantee was rejected as the CIT(A), applying tribunal jurisprudence, correctly directed benchmarking at 1% and recomputation of ALP; the CIT(A)'s order was affirmed and the Revenue's grounds were dismissed for both AYs. Downward adjustment under s. 80-IA(8) relating to wheeled/banked wind power adjusted against captive consumption was rejected by applying precedent on identical facts; the CIT(A)'s relief was upheld and the Revenue's appeal was dismissed. Case-Laws Income Tax Wed, 07 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465733