https://www.taxtmi.com/caselaws?id=797220 The APA under section 92CC governs recomputation of transfer-pricing adjustments for covered AMP expenditure, royalty, service-warranty charges and management-related expenses, using the prescribed Other Method and arm's length price mechanism. Expatriate salaries are deductible as business expenditure where expatriates work exclusively under the taxpayer's control and supervision and are remunerated by it. Royalty paid to parent entities is not capital expenditure where consistently accepted in earlier years and covered by the APA. Scientifically and rationally determined service-warranty provisions are deductible. The Indo-Korea DTAA claim concerning dividend distribution tax requires action after final Supreme Court adjudication on DDT's nature and treaty treatment. en-us Tue, 21 Jul 2026 00:00:00 +0530 Wed, 19 Aug 2026 08:20:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797220 The APA under section 92CC governs recomputation of transfer-pricing adjustments for covered AMP expenditure, royalty, service-warranty charges and management-related expenses, using the prescribed Other Method and arm's length price mechanism. Expatriate salaries are deductible as business expenditure where expatriates work exclusively under the taxpayer's control and supervision and are remunerated by it. Royalty paid to parent entities is not capital expenditure where consistently accepted in earlier years and covered by the APA. Scientifically and rationally determined service-warranty provisions are deductible. The Indo-Korea DTAA claim concerning dividend distribution tax requires action after final Supreme Court adjudication on DDT's nature and treaty treatment. Case-Laws Income Tax Tue, 21 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797220