https://www.taxtmi.com/caselaws?id=471795 Royalty on bought-out components subjected to further processing, and on technology-supported development, installation and commissioning activities, cannot be assigned a nil arm's length price merely under a benefit test where TNMM benchmarks closely linked transactions and no basis exists to disregard or recharacterise the arrangement. Management-fee costs require verification of services actually received and the allocation basis; the related entity-level TNMM analysis consequently requires recomputation. Employees' PF and ESI contributions paid after the statutory due date remain non-deductible despite payment before the income-tax return due date. No disallowance for expenditure relating to exempt income arises without exempt income, subject to verification of sufficient interest-free funds, and such disallowance does not increase book profit. en-us Fri, 08 Sep 2023 00:00:00 +0530 Fri, 18 Sep 2026 14:30:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471795 Royalty on bought-out components subjected to further processing, and on technology-supported development, installation and commissioning activities, cannot be assigned a nil arm's length price merely under a benefit test where TNMM benchmarks closely linked transactions and no basis exists to disregard or recharacterise the arrangement. Management-fee costs require verification of services actually received and the allocation basis; the related entity-level TNMM analysis consequently requires recomputation. Employees' PF and ESI contributions paid after the statutory due date remain non-deductible despite payment before the income-tax return due date. No disallowance for expenditure relating to exempt income arises without exempt income, subject to verification of sufficient interest-free funds, and such disallowance does not increase book profit. Case-Laws Income Tax Fri, 08 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471795