https://www.taxtmi.com/caselaws?id=472061 Transfer-pricing adjustment of AMP expenditure requires first identifying an international transaction; unilateral expenditure without a contractual arrangement or associated-enterprise benefit required fresh factual verification. Royalty paid under licensing arrangements could not be restricted ad hoc or valued at nil where accepted in earlier years without material change, so the adjustment was deleted. IT-support, technical/R&D services and chargebacks required renewed functional and comparability analysis, including whether recoveries were cost-to-cost reimbursements or service consideration. Share acquisition, ordinarily a capital account transaction not yielding taxable income, required examination under Section 56(2)(viib). Employee-based allocation of residual corporate costs was to continue if profit-linked deductions remained available. Book-profit treatment of tax-refund interest and treaty relief on dividends required fresh consideration after hearing the taxpayer. en-us Thu, 21 May 2026 00:00:00 +0530 Mon, 28 Sep 2026 20:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472061 Transfer-pricing adjustment of AMP expenditure requires first identifying an international transaction; unilateral expenditure without a contractual arrangement or associated-enterprise benefit required fresh factual verification. Royalty paid under licensing arrangements could not be restricted ad hoc or valued at nil where accepted in earlier years without material change, so the adjustment was deleted. IT-support, technical/R&D services and chargebacks required renewed functional and comparability analysis, including whether recoveries were cost-to-cost reimbursements or service consideration. Share acquisition, ordinarily a capital account transaction not yielding taxable income, required examination under Section 56(2)(viib). Employee-based allocation of residual corporate costs was to continue if profit-linked deductions remained available. Book-profit treatment of tax-refund interest and treaty relief on dividends required fresh consideration after hearing the taxpayer. Case-Laws Income Tax Thu, 21 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472061