https://www.taxtmi.com/caselaws?id=468394 Transfer pricing adjustments cannot survive where the underlying TPO order is time-barred. Bank charges and head-office or overseas-branch expenses were treated as deductible branch business expenditure, while related reimbursements were not taxable as benefits or perquisites. Country-risk provisioning remained non-deductible as contingent, but higher depreciation on business-use motor vehicles was allowable. Treaty provisions governed taxability of head-office and overseas-branch allocations, interest and refund interest, substantially deleting FTS and interest additions and restricting commission attribution to prevent double taxation. Back-to-back guarantees required fresh benchmarking, whereas derivative marketing adjustments lacked support and were deleted. en-us Mon, 10 Mar 2025 00:00:00 +0530 Mon, 04 May 2026 11:35:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468394 Transfer pricing adjustments cannot survive where the underlying TPO order is time-barred. Bank charges and head-office or overseas-branch expenses were treated as deductible branch business expenditure, while related reimbursements were not taxable as benefits or perquisites. Country-risk provisioning remained non-deductible as contingent, but higher depreciation on business-use motor vehicles was allowable. Treaty provisions governed taxability of head-office and overseas-branch allocations, interest and refund interest, substantially deleting FTS and interest additions and restricting commission attribution to prevent double taxation. Back-to-back guarantees required fresh benchmarking, whereas derivative marketing adjustments lacked support and were deleted. Case-Laws Income Tax Mon, 10 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468394