https://www.taxtmi.com/caselaws?id=799769 Cost-to-cost reimbursements supported by evidence and unconnected with any embedded mark-up, inflated pricing, or non-business expenditure do not justify a transfer-pricing adjustment without an identified comparable or uncontrolled price under the Other Method; the adjustment is deleted. Foreign tax credit is confined to the assessment year in which the corresponding income is taxed in India and cannot be carried forward or recast as a later-year business deduction where Indian tax liability is insufficient; the deduction claim is disallowed. Payments to non-residents for overseas recruitment, legal, and tariff-publication services require withholding only if chargeable to tax in India. As the services were not taxable technical, managerial, or consultancy services and did not make available technical knowledge, the disallowance is deleted. en-us Wed, 16 Sep 2026 00:00:00 +0530 Sat, 26 Sep 2026 08:31:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799769 Cost-to-cost reimbursements supported by evidence and unconnected with any embedded mark-up, inflated pricing, or non-business expenditure do not justify a transfer-pricing adjustment without an identified comparable or uncontrolled price under the Other Method; the adjustment is deleted. Foreign tax credit is confined to the assessment year in which the corresponding income is taxed in India and cannot be carried forward or recast as a later-year business deduction where Indian tax liability is insufficient; the deduction claim is disallowed. Payments to non-residents for overseas recruitment, legal, and tariff-publication services require withholding only if chargeable to tax in India. As the services were not taxable technical, managerial, or consultancy services and did not make available technical knowledge, the disallowance is deleted. Case-Laws Income Tax Wed, 16 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799769