https://www.taxtmi.com/caselaws?id=795913 Employee stock-option settlement costs paid to a group entity upon allotment or conversion of stock units are treated as employee compensation incurred for business purposes and deductible as revenue expenditure under Section 37(1), where the corresponding vesting-period provision had been added back and no material factual change exists. For transfer pricing, an operating margin agreed in a Bilateral Advance Pricing Agreement for IT and IT-enabled support services may be applied to an otherwise uncovered Associated Enterprise transaction where the services, functional profile and circumstances are identical. The adjustment is consequently limited to aligning the uncovered transaction's margin with the agreed APA margin. en-us Wed, 15 Apr 2026 00:00:00 +0530 Wed, 29 Jul 2026 08:21:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795913 Employee stock-option settlement costs paid to a group entity upon allotment or conversion of stock units are treated as employee compensation incurred for business purposes and deductible as revenue expenditure under Section 37(1), where the corresponding vesting-period provision had been added back and no material factual change exists. For transfer pricing, an operating margin agreed in a Bilateral Advance Pricing Agreement for IT and IT-enabled support services may be applied to an otherwise uncovered Associated Enterprise transaction where the services, functional profile and circumstances are identical. The adjustment is consequently limited to aligning the uncovered transaction's margin with the agreed APA margin. Case-Laws Income Tax Wed, 15 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795913