https://www.taxtmi.com/caselaws?id=790698 Transfer pricing adjustment on ESOP or RSU employee perquisite value was held unsustainable where the assessee incurred no actual cost and recorded no corresponding liability. The relevant arm's length computation required profit margin to be derived from costs actually incurred, and "incurred" was read as an existing financial obligation or outflow. Because the foreign parent granted the shares, the assessee neither acquired the shares nor bore the grant cost, and the TDS reimbursement was treated as a reimbursement without mark-up. A hypothetical or notional cost could not be imputed for transfer pricing purposes, and the adjustment was deleted. en-us Wed, 25 Mar 2026 00:00:00 +0530 Wed, 29 Apr 2026 08:16:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790698 Transfer pricing adjustment on ESOP or RSU employee perquisite value was held unsustainable where the assessee incurred no actual cost and recorded no corresponding liability. The relevant arm's length computation required profit margin to be derived from costs actually incurred, and "incurred" was read as an existing financial obligation or outflow. Because the foreign parent granted the shares, the assessee neither acquired the shares nor bore the grant cost, and the TDS reimbursement was treated as a reimbursement without mark-up. A hypothetical or notional cost could not be imputed for transfer pricing purposes, and the adjustment was deleted. Case-Laws Income Tax Wed, 25 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790698