https://www.taxtmi.com/caselaws?id=797073 Transfer-pricing adjustments for idle capacity, customs duty, provision reversals, miscellaneous receipts, business-support income, comparables, marketing-support characterisation and AE/non-AE segmentation require fresh verification on supporting evidence. Provision reversals may receive operating treatment where the original provisions were operating expenses, while business-support income is non-operating with corresponding expenses excluded. Opening inventory must be adjusted after verification where an obsolescence provision was disallowed previously. Foreign-exchange loss on ECB borrowings used for domestic assets after the assets are put to use is revenue expenditure where the foreign-asset rule does not apply. Software application licences qualify for computer-rate depreciation. Salary reimbursements for seconded employees under the recipient's control, already subject to salary withholding, are not separately taxable as technical-service fees. en-us Fri, 07 Aug 2026 00:00:00 +0530 Mon, 17 Aug 2026 08:38:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797073 Transfer-pricing adjustments for idle capacity, customs duty, provision reversals, miscellaneous receipts, business-support income, comparables, marketing-support characterisation and AE/non-AE segmentation require fresh verification on supporting evidence. Provision reversals may receive operating treatment where the original provisions were operating expenses, while business-support income is non-operating with corresponding expenses excluded. Opening inventory must be adjusted after verification where an obsolescence provision was disallowed previously. Foreign-exchange loss on ECB borrowings used for domestic assets after the assets are put to use is revenue expenditure where the foreign-asset rule does not apply. Software application licences qualify for computer-rate depreciation. Salary reimbursements for seconded employees under the recipient's control, already subject to salary withholding, are not separately taxable as technical-service fees. Case-Laws Income Tax Fri, 07 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797073