https://www.taxtmi.com/caselaws?id=790225 Export incentives under the Merchandise Exports from India Scheme and duty drawback income were treated as operating revenue for transfer pricing because they were directly linked to normal manufacturing and export operations, formed part of operating revenue in the accounts, and their exclusion would distort the profit level indicator; the adjustment was made in favour of the assessee. Working capital adjustment was also directed as necessary on the material already placed before the authorities to ensure a fair arm's length comparison. Deduction under section 80G was allowed because a donation made out of CSR expenditure cannot be denied on any restriction beyond the statutory exclusions expressly provided in the Act. en-us Tue, 30 Dec 2025 00:00:00 +0530 Mon, 20 Apr 2026 15:46:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790225 Export incentives under the Merchandise Exports from India Scheme and duty drawback income were treated as operating revenue for transfer pricing because they were directly linked to normal manufacturing and export operations, formed part of operating revenue in the accounts, and their exclusion would distort the profit level indicator; the adjustment was made in favour of the assessee. Working capital adjustment was also directed as necessary on the material already placed before the authorities to ensure a fair arm's length comparison. Deduction under section 80G was allowed because a donation made out of CSR expenditure cannot be denied on any restriction beyond the statutory exclusions expressly provided in the Act. Case-Laws Income Tax Tue, 30 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790225