https://www.taxtmi.com/highlights?id=96657 Transfer pricing adjustments on corporate guarantee commission and interest on convertible loans were rejected because identical issues were previously decided in favour of the taxpayer by the ITAT; outcome: adjustments deleted. Reimbursement of expenses was held at arm's length on documentary proof and past ITAT precedent; outcome: adjustment denied. Sale of goods to an AE benchmarked using Compustat North America fell within the 3% safe harbour margin and the adjustment was dismissed. Three rejected comparables were accepted as functionally and jurisdictionally comparable; outcome: AO/TPO rejection overturned. DIANE database search for a later year failed Rule 10CA requirements; outcome: comparable search rejected. Claim for weighted R&D deduction limited to expenditure approved by the competent authority was upheld; outcome: deduction restricted to DSIR-approved quantum. en-us Fri, 06 Feb 2026 10:08:41 +0530 Fri, 06 Feb 2026 10:08:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=96657 Transfer pricing adjustments on corporate guarantee commission and interest on convertible loans were rejected because identical issues were previously decided in favour of the taxpayer by the ITAT; outcome: adjustments deleted. Reimbursement of expenses was held at arm's length on documentary proof and past ITAT precedent; outcome: adjustment denied. Sale of goods to an AE benchmarked using Compustat North America fell within the 3% safe harbour margin and the adjustment was dismissed. Three rejected comparables were accepted as functionally and jurisdictionally comparable; outcome: AO/TPO rejection overturned. DIANE database search for a later year failed Rule 10CA requirements; outcome: comparable search rejected. Claim for weighted R&D deduction limited to expenditure approved by the competent authority was upheld; outcome: deduction restricted to DSIR-approved quantum. Highlights Income Tax Fri, 06 Feb 2026 10:08:41 +0530 https://www.taxtmi.com/highlights?id=96657