https://www.taxtmi.com/caselaws?id=796511 Revenue treatment of licence or royalty payments is supported where the expenditure is incurred in the ordinary course of business and facts remain unchanged. Warranty provisions based on historical experience and scientific estimation constitute accrued, rather than contingent, liabilities. For transfer pricing, comparables must be functionally aligned: product-focused, R&D-intensive or intangible-owning companies without reliable segmental data may be excluded, while software service providers may be included. The notes address fresh working-capital and capacity-utilisation adjustments, operating treatment of manufacturing-related foreign-exchange fluctuation, restriction of adjustments to associated-enterprise transactions, exclusion of goodwill amortisation from operating costs, and customs-duty adjustments for materially higher import content. en-us Thu, 23 Jul 2026 00:00:00 +0530 Thu, 06 Aug 2026 09:11:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796511 Revenue treatment of licence or royalty payments is supported where the expenditure is incurred in the ordinary course of business and facts remain unchanged. Warranty provisions based on historical experience and scientific estimation constitute accrued, rather than contingent, liabilities. For transfer pricing, comparables must be functionally aligned: product-focused, R&D-intensive or intangible-owning companies without reliable segmental data may be excluded, while software service providers may be included. The notes address fresh working-capital and capacity-utilisation adjustments, operating treatment of manufacturing-related foreign-exchange fluctuation, restriction of adjustments to associated-enterprise transactions, exclusion of goodwill amortisation from operating costs, and customs-duty adjustments for materially higher import content. Case-Laws Income Tax Thu, 23 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796511