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    <title>Businessman&#039;s perspective governs managerial remuneration; rupee debenture interest benchmarks to Prime Lending Rate for arm&#039;s length testing.</title>
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    <description>Employee benefit expenses were not to be disallowed merely because managerial remuneration increased while revenue declined, where the expenditure was genuine, business-related and supported by material showing services rendered. The reasonableness of remuneration had to be judged from the businessman&#039;s perspective, not on the Assessing Officer&#039;s subjective view, and the Rule 46A objection failed because the relied-on documents were not treated as additional evidence requiring remand. On transfer pricing, interest on rupee-denominated non-convertible debentures was benchmarked against the Prime Lending Rate, not EBLR; on that basis the coupon rate was treated as arm&#039;s length and the adjustment was deleted.</description>
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      <description>Employee benefit expenses were not to be disallowed merely because managerial remuneration increased while revenue declined, where the expenditure was genuine, business-related and supported by material showing services rendered. The reasonableness of remuneration had to be judged from the businessman&#039;s perspective, not on the Assessing Officer&#039;s subjective view, and the Rule 46A objection failed because the relied-on documents were not treated as additional evidence requiring remand. On transfer pricing, interest on rupee-denominated non-convertible debentures was benchmarked against the Prime Lending Rate, not EBLR; on that basis the coupon rate was treated as arm&#039;s length and the adjustment was deleted.</description>
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