https://www.taxtmi.com/caselaws?id=472293 Foreign-currency loans advanced to overseas associated enterprises require an economically comparable arm's-length benchmark; LIBOR-linked rates are appropriate where the loans are received and used abroad, unlike Indian corporate-bond yields. A royalty CUP comparison requires materially comparable uncontrolled transactions, including comparable territories, trademarks, products and market conditions; an undisplaced TNMM analysis supports the existing royalty treatment. Recurring market research for established products remains revenue expenditure where it creates no identifiable capital asset, and unsupported ad hoc expense disallowances are not sustainable. For industrial-undertaking deductions, manufacturing by-product and scrap sales satisfy the direct-nexus requirement, whereas machinery lease rent does not. en-us Fri, 01 Mar 2019 00:00:00 +0530 Wed, 07 Oct 2026 18:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472293 Foreign-currency loans advanced to overseas associated enterprises require an economically comparable arm's-length benchmark; LIBOR-linked rates are appropriate where the loans are received and used abroad, unlike Indian corporate-bond yields. A royalty CUP comparison requires materially comparable uncontrolled transactions, including comparable territories, trademarks, products and market conditions; an undisplaced TNMM analysis supports the existing royalty treatment. Recurring market research for established products remains revenue expenditure where it creates no identifiable capital asset, and unsupported ad hoc expense disallowances are not sustainable. For industrial-undertaking deductions, manufacturing by-product and scrap sales satisfy the direct-nexus requirement, whereas machinery lease rent does not. Case-Laws Income Tax Fri, 01 Mar 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472293