https://www.taxtmi.com/caselaws?id=466904 The tribunal addressed multiple tax issues: it held that a corporate guarantee constitutes an international transaction and directed an arm's length upward adjustment at 0.5% favouring the taxpayer; a one time brand usage payment is revenue in nature and allowed; a warranty provision meets the present obligation and reliable estimate test and is deductible; engineering/technical service fees for projects performed and utilised abroad do not accrue in India and attract no TDS; entitlement to infrastructure deductions under section 80IA and ESOP amortization were remitted to the assessing officer for factual determination; capitalised ERP costs qualify for depreciation despite non deduction, and the nature of a marketing fee to a non resident was remitted for determination. en-us Thu, 31 Aug 2023 00:00:00 +0530 Tue, 24 Feb 2026 15:06:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466904 The tribunal addressed multiple tax issues: it held that a corporate guarantee constitutes an international transaction and directed an arm's length upward adjustment at 0.5% favouring the taxpayer; a one time brand usage payment is revenue in nature and allowed; a warranty provision meets the present obligation and reliable estimate test and is deductible; engineering/technical service fees for projects performed and utilised abroad do not accrue in India and attract no TDS; entitlement to infrastructure deductions under section 80IA and ESOP amortization were remitted to the assessing officer for factual determination; capitalised ERP costs qualify for depreciation despite non deduction, and the nature of a marketing fee to a non resident was remitted for determination. Case-Laws Income Tax Thu, 31 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466904