https://www.taxtmi.com/caselaws?id=799949 The restriction on eligible-unit deductions for transfer-pricing adjustments applies where tax authorities enhance income through an arm's-length-price determination, not where the taxpayer voluntarily computes and returns the adjustment as business income. Exempt-income expenditure cannot be disallowed on an ad hoc basis where investments have no opening or closing balance, own funds are sufficient, and no related expenditure is identified. Foreign-exchange fluctuation loss recognised at the balance-sheet date is allowable business expenditure. For captive ITeS transactions, comparables may be excluded when functionally dissimilar, lacking reliable segmental data, or failing related-party-transaction or employee-cost filters; prior functional analysis may be followed where material facts remain unchanged. en-us Mon, 21 Sep 2026 00:00:00 +0530 Tue, 29 Sep 2026 08:34:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799949 The restriction on eligible-unit deductions for transfer-pricing adjustments applies where tax authorities enhance income through an arm's-length-price determination, not where the taxpayer voluntarily computes and returns the adjustment as business income. Exempt-income expenditure cannot be disallowed on an ad hoc basis where investments have no opening or closing balance, own funds are sufficient, and no related expenditure is identified. Foreign-exchange fluctuation loss recognised at the balance-sheet date is allowable business expenditure. For captive ITeS transactions, comparables may be excluded when functionally dissimilar, lacking reliable segmental data, or failing related-party-transaction or employee-cost filters; prior functional analysis may be followed where material facts remain unchanged. Case-Laws Income Tax Mon, 21 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799949