https://www.taxtmi.com/caselaws?id=800720 Employee stock-option discounts incurred to secure services during the vesting period are ascertained revenue expenditure deductible under Section 37(1), despite no cash outflow. For transfer pricing, associated-enterprise status requires a conjunctive assessment, and royalty benchmarking should examine reliable internal uncontrolled transactions and comparable third-party agreements before external comparables. Comparable selection across trading, IT-support, and digital-marketing segments must reflect functional, asset and risk similarity; entities affected by extraordinary events, lacking reliable segmental data, or owning material intangibles may require exclusion. Rule 10AB permits gross-margin comparison under the other method where relevant data support it, while Rule 10CA(2) restricts retention of a non-comparable entity in multi-year analysis. en-us Tue, 29 Sep 2026 00:00:00 +0530 Sat, 10 Oct 2026 08:32:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800720 Employee stock-option discounts incurred to secure services during the vesting period are ascertained revenue expenditure deductible under Section 37(1), despite no cash outflow. For transfer pricing, associated-enterprise status requires a conjunctive assessment, and royalty benchmarking should examine reliable internal uncontrolled transactions and comparable third-party agreements before external comparables. Comparable selection across trading, IT-support, and digital-marketing segments must reflect functional, asset and risk similarity; entities affected by extraordinary events, lacking reliable segmental data, or owning material intangibles may require exclusion. Rule 10AB permits gross-margin comparison under the other method where relevant data support it, while Rule 10CA(2) restricts retention of a non-comparable entity in multi-year analysis. Case-Laws Income Tax Tue, 29 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800720