https://www.taxtmi.com/caselaws?id=789035 Transfer pricing adjustment on AMP expenditure was deleted where the brand belonged to the assessee and the bright line test was found inapplicable, while the restricted adjustment for ticketing and tour management services was sustained on the facts. Disallowance under section 40(a)(ia) was deleted for payment gateway charges and air ticket costs paid through MMT US because no taxable technical, commission or included service was established, and the treaty make-available test was not met. Deferred revenue receipts under the Amadeus and Apollo DKV agreements were held taxable only on accrual over the contract term, not in full on receipt. ESOP-related expenditure was allowed as revenue in nature. en-us Wed, 25 Mar 2026 00:00:00 +0530 Thu, 02 Apr 2026 08:50:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789035 Transfer pricing adjustment on AMP expenditure was deleted where the brand belonged to the assessee and the bright line test was found inapplicable, while the restricted adjustment for ticketing and tour management services was sustained on the facts. Disallowance under section 40(a)(ia) was deleted for payment gateway charges and air ticket costs paid through MMT US because no taxable technical, commission or included service was established, and the treaty make-available test was not met. Deferred revenue receipts under the Amadeus and Apollo DKV agreements were held taxable only on accrual over the contract term, not in full on receipt. ESOP-related expenditure was allowed as revenue in nature. Case-Laws Income Tax Wed, 25 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789035