https://www.taxtmi.com/caselaws?id=797896 Pure third-party expenditure reimbursements recovered from group entities at cost, without value addition or services to associated enterprises, are not subject to a transfer-pricing mark-up; deletion remains subject to verification. Overseas salary and wage cross-charges may attract adjustment where service-sharing evidence, including records or log sheets, is inadequate. Licence-fee payments for television distribution rights require Comparable Uncontrolled Price benchmarking using functionally comparable licence agreements rather than software or IT-distributor comparables, with identified agreements requiring consideration. Foreign taxes ineligible for credit may be claimed as a deduction subject to verification of supporting foreign-tax-credit particulars, Form 67 and withholding-tax certificates under applicable law. en-us Fri, 21 Aug 2026 00:00:00 +0530 Sat, 29 Aug 2026 14:35:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797896 Pure third-party expenditure reimbursements recovered from group entities at cost, without value addition or services to associated enterprises, are not subject to a transfer-pricing mark-up; deletion remains subject to verification. Overseas salary and wage cross-charges may attract adjustment where service-sharing evidence, including records or log sheets, is inadequate. Licence-fee payments for television distribution rights require Comparable Uncontrolled Price benchmarking using functionally comparable licence agreements rather than software or IT-distributor comparables, with identified agreements requiring consideration. Foreign taxes ineligible for credit may be claimed as a deduction subject to verification of supporting foreign-tax-credit particulars, Form 67 and withholding-tax certificates under applicable law. Case-Laws Income Tax Fri, 21 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797896