https://www.taxtmi.com/caselaws?id=788636 Transfer pricing adjustment on export transactions to foreign associated enterprises was deleted because the tested-party selection had already been accepted in an earlier year and the Revenue showed no distinguishing feature to depart from that consistent approach. Section 41(1) required evidence of remission or cessation, not mere pendency of creditors; section 35(2AB) was satisfied by DSIR approval of the R&D facility before the Rule 6(7A) amendment; and interest allocation to eligible units was unwarranted where own funds were sufficient. Disallowance under section 14A was confined to exempt income and could not be imported into section 115JB absent statutory basis. Excise duty exemption was treated as a capital receipt, while some export incentive issues and deduction under section 32AC were sent back for reconsideration. en-us Thu, 12 Mar 2026 00:00:00 +0530 Wed, 25 Mar 2026 11:28:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788636 Transfer pricing adjustment on export transactions to foreign associated enterprises was deleted because the tested-party selection had already been accepted in an earlier year and the Revenue showed no distinguishing feature to depart from that consistent approach. Section 41(1) required evidence of remission or cessation, not mere pendency of creditors; section 35(2AB) was satisfied by DSIR approval of the R&D facility before the Rule 6(7A) amendment; and interest allocation to eligible units was unwarranted where own funds were sufficient. Disallowance under section 14A was confined to exempt income and could not be imported into section 115JB absent statutory basis. Excise duty exemption was treated as a capital receipt, while some export incentive issues and deduction under section 32AC were sent back for reconsideration. Case-Laws Income Tax Thu, 12 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788636