https://www.taxtmi.com/caselaws?id=785781 Cross-border payments to an associated enterprise were scrutinised for classification as Fees for Included Services under the "make available" concept and for TDS non-deduction leading to disallowance for failure of withholding. The tribunal found the assessee failed to substantiate large reimbursements (notably process outsourcing and shared administrative costs), directed allowance of substantiated marketing expenses and authorised AO to restrict unsubstantiated administrative/marketing reimbursements to 20% while giving hearing opportunity. Separately, repeated creation of provisions for customer refunds was held to require verification and historical reconciliation; the issue is remitted to the AO for factual examination and adjustment. en-us Mon, 05 Jan 2026 00:00:00 +0530 Sat, 31 Jan 2026 08:55:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785781 Cross-border payments to an associated enterprise were scrutinised for classification as Fees for Included Services under the "make available" concept and for TDS non-deduction leading to disallowance for failure of withholding. The tribunal found the assessee failed to substantiate large reimbursements (notably process outsourcing and shared administrative costs), directed allowance of substantiated marketing expenses and authorised AO to restrict unsubstantiated administrative/marketing reimbursements to 20% while giving hearing opportunity. Separately, repeated creation of provisions for customer refunds was held to require verification and historical reconciliation; the issue is remitted to the AO for factual examination and adjustment. Case-Laws Income Tax Mon, 05 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785781