https://www.taxtmi.com/caselaws?id=800894 Cost-to-cost reimbursement of salary and travel costs for temporarily seconded employees did not warrant a transfer-pricing mark-up where it was not consideration for a continuing service, had been consistently accepted, and was recognised in a bilateral advance pricing agreement. Under the rule of consistency, no contrary treatment applied without changed facts. Amalgamation expenditure incurred and paid after approval was amortised over five years from the year of actual incurrence, since computation from an earlier appointed date would require deduction before the expenditure was incurred and offend the principle of impossibility of performance. The fifth annual deduction was therefore available for the relevant assessment year. en-us Wed, 30 Sep 2026 00:00:00 +0530 Tue, 13 Oct 2026 07:21:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800894 Cost-to-cost reimbursement of salary and travel costs for temporarily seconded employees did not warrant a transfer-pricing mark-up where it was not consideration for a continuing service, had been consistently accepted, and was recognised in a bilateral advance pricing agreement. Under the rule of consistency, no contrary treatment applied without changed facts. Amalgamation expenditure incurred and paid after approval was amortised over five years from the year of actual incurrence, since computation from an earlier appointed date would require deduction before the expenditure was incurred and offend the principle of impossibility of performance. The fifth annual deduction was therefore available for the relevant assessment year. Case-Laws Income Tax Wed, 30 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800894