<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>Transfer pricing and PF/ESI timing issues led to deletion of management fee adjustment, restricted royalty, and sustained disallowance</title>
    <link>https://www.taxtmi.com/highlights?id=100678</link>
    <description>Transfer pricing adjustments on intra-group management charges were deleted after accepting the assessee&#039;s TNMM benchmarking and rejecting a nil arm&#039;s length value. Royalty on sales was restricted by allowing 5% on both sales to associated enterprises and third parties, as the authorities could not disallow the entire payment or treat the assessee as a contract manufacturer for this purpose. For outstanding receivables, working capital adjustment had to be given first; only any remaining shortfall could be examined again for interest adjustment, so the issue was restored for fresh determination. Disallowance of employees&#039; PF and ESI contribution deposited after the welfare law due date was sustained, as later payment within the income-tax filing timeline did not cure the default.</description>
    <language>en-us</language>
    <pubDate>Thu, 11 Jun 2026 11:31:00 +0530</pubDate>
    <lastBuildDate>Thu, 11 Jun 2026 11:31:00 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=906515" rel="self" type="application/rss+xml"/>
    <item>
      <title>Transfer pricing and PF/ESI timing issues led to deletion of management fee adjustment, restricted royalty, and sustained disallowance</title>
      <link>https://www.taxtmi.com/highlights?id=100678</link>
      <description>Transfer pricing adjustments on intra-group management charges were deleted after accepting the assessee&#039;s TNMM benchmarking and rejecting a nil arm&#039;s length value. Royalty on sales was restricted by allowing 5% on both sales to associated enterprises and third parties, as the authorities could not disallow the entire payment or treat the assessee as a contract manufacturer for this purpose. For outstanding receivables, working capital adjustment had to be given first; only any remaining shortfall could be examined again for interest adjustment, so the issue was restored for fresh determination. Disallowance of employees&#039; PF and ESI contribution deposited after the welfare law due date was sustained, as later payment within the income-tax filing timeline did not cure the default.</description>
      <category>Highlights</category>
      <law>Income Tax</law>
      <pubDate>Thu, 11 Jun 2026 11:31:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/highlights?id=100678</guid>
    </item>
  </channel>
</rss>