https://www.taxtmi.com/caselaws?id=792585 Transfer pricing adjustments for advertising, marketing and promotional expenditure were rejected where brand-building allocation was not shown to justify shifting value to the overseas IPR owner. Section 14A disallowance was declined in the absence of exempt income, and disallowances could not be sustained on seized material from non-coincident assessment years. The Supreme Court also noted an unexplained delay of 384 days in filing the Special Leave Petition and found no ground to interfere with the High Court's order, so the SLP was dismissed on delay as well as on merits. en-us Tue, 26 May 2026 00:00:00 +0530 Sat, 30 May 2026 08:29:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792585 Transfer pricing adjustments for advertising, marketing and promotional expenditure were rejected where brand-building allocation was not shown to justify shifting value to the overseas IPR owner. Section 14A disallowance was declined in the absence of exempt income, and disallowances could not be sustained on seized material from non-coincident assessment years. The Supreme Court also noted an unexplained delay of 384 days in filing the Special Leave Petition and found no ground to interfere with the High Court's order, so the SLP was dismissed on delay as well as on merits. Case-Laws Income Tax Tue, 26 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792585