https://www.taxtmi.com/caselaws?id=793290 Internal TNMM was accepted over CUP for benchmarking finished-goods sales to associated enterprises because the AE and non-AE transactions differed materially in contractual terms, economic circumstances, volumes, payment terms and functions; the CUP adjustment was deleted. Sales promotion and marketing services from AEs were held to be evidenced and at arm's length, so the adjustment was deleted. Additional depreciation was denied on replacement spares and parts because this was not acquisition of new plant and machinery, but allowed on tanks as part of eligible plant. Prior period expenses were not an authorised adjustment under section 115JB, so the book-profit addition was deleted. Interest on capital work in progress could not be capitalised without a proved nexus between borrowings and fixed assets. Weighted deduction under section 35(2AB) could not be restricted merely because Form 3CL did not quantify expenditure for that year. en-us Wed, 10 Jun 2026 00:00:00 +0530 Fri, 12 Jun 2026 08:45:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793290 Internal TNMM was accepted over CUP for benchmarking finished-goods sales to associated enterprises because the AE and non-AE transactions differed materially in contractual terms, economic circumstances, volumes, payment terms and functions; the CUP adjustment was deleted. Sales promotion and marketing services from AEs were held to be evidenced and at arm's length, so the adjustment was deleted. Additional depreciation was denied on replacement spares and parts because this was not acquisition of new plant and machinery, but allowed on tanks as part of eligible plant. Prior period expenses were not an authorised adjustment under section 115JB, so the book-profit addition was deleted. Interest on capital work in progress could not be capitalised without a proved nexus between borrowings and fixed assets. Weighted deduction under section 35(2AB) could not be restricted merely because Form 3CL did not quantify expenditure for that year. Case-Laws Income Tax Wed, 10 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793290