https://www.taxtmi.com/caselaws?id=795355 Transfer-pricing analysis addresses royalty and commission paid to associated enterprises, stressing that Comparable Uncontrolled Price benchmarking requires reliable functional, contractual and economic comparability, while aggregated Transactional Net Margin Method results may require reassessment. The note records deletion of royalty adjustments and remand of commission benchmarking. It also addresses capital-gains indexation and allocation of transfer expenses, statutory relocation relief for plant and machinery investment, and verification of a subsequently reversed provision. Commission to non-resident agents for services rendered outside India is discussed as not taxable absent an Indian business connection or permanent establishment. For exempt-income expenditure, sufficient own funds, absence of a borrowing nexus and recorded satisfaction are identified as material to disallowance. 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 Transfer-pricing analysis addresses royalty and commission paid to associated enterprises, stressing that Comparable Uncontrolled Price benchmarking requires reliable functional, contractual and economic comparability, while aggregated Transactional Net Margin Method results may require reassessment. The note records deletion of royalty adjustments and remand of commission benchmarking. It also addresses capital-gains indexation and allocation of transfer expenses, statutory relocation relief for plant and machinery investment, and verification of a subsequently reversed provision. Commission to non-resident agents for services rendered outside India is discussed as not taxable absent an Indian business connection or permanent establishment. For exempt-income expenditure, sufficient own funds, absence of a borrowing nexus and recorded satisfaction are identified as material to disallowance. Case-Laws Income Tax Fri, 17 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795355