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    <title>Transfer pricing on AE import pricing using CUP/RPM evidence upheld; adjustment deleted; foreign travel partly disallowed; 40(a)(i) dropped.</title>
    <link>https://www.taxtmi.com/highlights?id=95909</link>
    <description>Transfer pricing adjustment on imports from associated enterprise was deleted because the taxpayer had substantiated comparable uncontrolled prices with supporting bills, and the same CUP/RPM approach had been accepted in the immediately preceding remand proceedings and in subsequent years; applying the consistency principle, the deletion of the adjustment for manufacturing, trading, and services segments was upheld, dismissing the Revenue&#039;s ground. Ad hoc disallowance of foreign travel was restricted since the taxpayer had not been specifically called upon to furnish details; a 10% disallowance of total foreign travel expenditure was sustained, partly allowing the Revenue&#039;s ground. Disallowance under section 40(a)(i) for alleged non-deduct.....</description>
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    <pubDate>Sat, 10 Jan 2026 08:25:22 +0530</pubDate>
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      <title>Transfer pricing on AE import pricing using CUP/RPM evidence upheld; adjustment deleted; foreign travel partly disallowed; 40(a)(i) dropped.</title>
      <link>https://www.taxtmi.com/highlights?id=95909</link>
      <description>Transfer pricing adjustment on imports from associated enterprise was deleted because the taxpayer had substantiated comparable uncontrolled prices with supporting bills, and the same CUP/RPM approach had been accepted in the immediately preceding remand proceedings and in subsequent years; applying the consistency principle, the deletion of the adjustment for manufacturing, trading, and services segments was upheld, dismissing the Revenue&#039;s ground. Ad hoc disallowance of foreign travel was restricted since the taxpayer had not been specifically called upon to furnish details; a 10% disallowance of total foreign travel expenditure was sustained, partly allowing the Revenue&#039;s ground. Disallowance under section 40(a)(i) for alleged non-deduct.....</description>
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      <pubDate>Sat, 10 Jan 2026 08:25:22 +0530</pubDate>
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