https://www.taxtmi.com/caselaws?id=800340 Royalty payments inseparably linked to manufacturing and benchmarked under an aggregated TNMM approach should not be separately tested or recast as a cost contribution arrangement without a material change in facts; the related transfer-pricing adjustment is removed. Engineering and design comparables require functional similarity and reliable segmental data; a diversified entity lacking reliable segmental information and affected by an extraordinary acquisition should be excluded, requiring recomputation of the margin. Expenditure attributable to exempt income may be disallowed under Section 14A and amended Rule 8D once the Assessing Officer records dissatisfaction with the taxpayer's claim; the disallowance is sustained where personnel costs were omitted. en-us Mon, 28 Sep 2026 00:00:00 +0530 Mon, 05 Oct 2026 08:13:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800340 Royalty payments inseparably linked to manufacturing and benchmarked under an aggregated TNMM approach should not be separately tested or recast as a cost contribution arrangement without a material change in facts; the related transfer-pricing adjustment is removed. Engineering and design comparables require functional similarity and reliable segmental data; a diversified entity lacking reliable segmental information and affected by an extraordinary acquisition should be excluded, requiring recomputation of the margin. Expenditure attributable to exempt income may be disallowed under Section 14A and amended Rule 8D once the Assessing Officer records dissatisfaction with the taxpayer's claim; the disallowance is sustained where personnel costs were omitted. Case-Laws Income Tax Mon, 28 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800340