https://www.taxtmi.com/caselaws?id=787154 Transfer pricing adjustments on associated-enterprise loans and delayed receivables were deleted because internal CUP was accepted, external CUP and ad hoc forex loading were rejected, and TNMM with working-capital adjustment precluded separate notional interest. Goodwill arising from court-sanctioned amalgamation qualified as a depreciable business or commercial right, subject to the proportionate restriction for one eligible unit. Further common-expense allocation was rejected where unit accounts already captured those expenses. Research expenditure deduction could not be confined to Form 3CL for the relevant period. Interest disallowance failed absent a proven borrowing nexus, while sufficient own funds supported the investment presumption. No disallowance arose without exempt income, and overseas agent commission was not subject to withholding where services were rendered outside India without an Indian business connection or permanent establishment. en-us Tue, 24 Feb 2026 00:00:00 +0530 Tue, 04 Aug 2026 11:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787154 Transfer pricing adjustments on associated-enterprise loans and delayed receivables were deleted because internal CUP was accepted, external CUP and ad hoc forex loading were rejected, and TNMM with working-capital adjustment precluded separate notional interest. Goodwill arising from court-sanctioned amalgamation qualified as a depreciable business or commercial right, subject to the proportionate restriction for one eligible unit. Further common-expense allocation was rejected where unit accounts already captured those expenses. Research expenditure deduction could not be confined to Form 3CL for the relevant period. Interest disallowance failed absent a proven borrowing nexus, while sufficient own funds supported the investment presumption. No disallowance arose without exempt income, and overseas agent commission was not subject to withholding where services were rendered outside India without an Indian business connection or permanent establishment. Case-Laws Income Tax Tue, 24 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787154