https://www.taxtmi.com/caselaws?id=795355 Comparable Uncontrolled Price benchmarking of royalty and commission transactions requires reliable functional and economic comparability, including contractual terms, markets, functions, risks and commercial conditions. Domestic royalty rates cannot be applied to export sales without that analysis; royalty adjustments were deleted, while commission benchmarking requires fresh examination. Capital-gains indexation was confined to the year of registered acquisition and capitalisation, while transfer-expense allocation requires verification. A statutory relocation-relief claim cannot be rejected solely because no revised return was filed; investment conditions require verification. Non-resident export-agent commission was not taxable absent Indian services, business connection or permanent establishment. Exempt-income expenditure disallowance fails where sufficient own funds exist without a borrowing nexus and recorded satisfaction. en-us Fri, 17 Jul 2026 00:00:00 +0530 Tue, 21 Jul 2026 08:32:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795355 Comparable Uncontrolled Price benchmarking of royalty and commission transactions requires reliable functional and economic comparability, including contractual terms, markets, functions, risks and commercial conditions. Domestic royalty rates cannot be applied to export sales without that analysis; royalty adjustments were deleted, while commission benchmarking requires fresh examination. Capital-gains indexation was confined to the year of registered acquisition and capitalisation, while transfer-expense allocation requires verification. A statutory relocation-relief claim cannot be rejected solely because no revised return was filed; investment conditions require verification. Non-resident export-agent commission was not taxable absent Indian services, business connection or permanent establishment. Exempt-income expenditure disallowance fails where sufficient own funds exist without a borrowing nexus and recorded satisfaction. Case-Laws Income Tax Fri, 17 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795355