https://www.taxtmi.com/highlights?id=103210 Cost-to-cost reimbursements of third-party marketing, promotion, travel and other expenses involving no services or value addition do not warrant an upward transfer-pricing adjustment; domestic-group recoveries require verification. Salary and wage cross-charges from foreign associated enterprises remain subject to adjustment where shared employee services are insufficiently substantiated. Television-channel distribution licence fees should be benchmarked under the Comparable Uncontrolled Price method where comparable licence agreements exist; software and IT distributors are not functionally comparable. A foreign-tax deduction claim not made in the return may be raised before appellate authorities, but requires factual verification where tax credit was unavailable or unclaimed. en-us Sat, 29 Aug 2026 14:35:41 +0530 Sat, 29 Aug 2026 14:35:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103210 Cost-to-cost reimbursements of third-party marketing, promotion, travel and other expenses involving no services or value addition do not warrant an upward transfer-pricing adjustment; domestic-group recoveries require verification. Salary and wage cross-charges from foreign associated enterprises remain subject to adjustment where shared employee services are insufficiently substantiated. Television-channel distribution licence fees should be benchmarked under the Comparable Uncontrolled Price method where comparable licence agreements exist; software and IT distributors are not functionally comparable. A foreign-tax deduction claim not made in the return may be raised before appellate authorities, but requires factual verification where tax credit was unavailable or unclaimed. Highlights Income Tax Sat, 29 Aug 2026 14:35:41 +0530 https://www.taxtmi.com/highlights?id=103210