https://www.taxtmi.com/caselaws?id=800891 Technical know-how fees netted against the cost of premix purchased from an associated enterprise form part of closely linked transactions and may be aggregated under Rules 10A(d) and 10B. Where premix invoice prices are accepted under the comparable uncontrolled price method, the cost-reducing fee is treated as arm's length, precluding separate benchmarking and deleting the transfer-pricing adjustment. A Section 40A(2)(b) disallowance of directors' performance incentives requires evidence that expenditure is excessive or unreasonable against fair market value, business needs, or benefit derived. Without supporting findings or comparable evidence, the provision is not disallowable and the addition is deleted. en-us Tue, 29 Sep 2026 00:00:00 +0530 Tue, 13 Oct 2026 07:21:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800891 Technical know-how fees netted against the cost of premix purchased from an associated enterprise form part of closely linked transactions and may be aggregated under Rules 10A(d) and 10B. Where premix invoice prices are accepted under the comparable uncontrolled price method, the cost-reducing fee is treated as arm's length, precluding separate benchmarking and deleting the transfer-pricing adjustment. A Section 40A(2)(b) disallowance of directors' performance incentives requires evidence that expenditure is excessive or unreasonable against fair market value, business needs, or benefit derived. Without supporting findings or comparable evidence, the provision is not disallowable and the addition is deleted. Case-Laws Income Tax Tue, 29 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800891