https://www.taxtmi.com/caselaws?id=801047 Royalty payments for trademark and marketing know-how must be benchmarked separately from branded-product purchases under the Resale Price Method, which tests gross margins and does not absorb royalty incurred below the gross-profit level. A Comparable Uncontrolled Price adjustment cannot rely on unsigned, unexecuted franchise-agreement templates rather than actual uncontrolled transactions; the royalty adjustment was deleted. Restricted stock-unit costs, shared IT support charges, and recurring tester, advertising, and sales-promotion expenditure qualified as business expenditure under Section 37(1), resulting in deletion of the related disallowances. Set-off of brought-forward business losses and unabsorbed depreciation requires verification and allowance in accordance with law. en-us Tue, 11 Aug 2026 00:00:00 +0530 Thu, 15 Oct 2026 05:44:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801047 Royalty payments for trademark and marketing know-how must be benchmarked separately from branded-product purchases under the Resale Price Method, which tests gross margins and does not absorb royalty incurred below the gross-profit level. A Comparable Uncontrolled Price adjustment cannot rely on unsigned, unexecuted franchise-agreement templates rather than actual uncontrolled transactions; the royalty adjustment was deleted. Restricted stock-unit costs, shared IT support charges, and recurring tester, advertising, and sales-promotion expenditure qualified as business expenditure under Section 37(1), resulting in deletion of the related disallowances. Set-off of brought-forward business losses and unabsorbed depreciation requires verification and allowance in accordance with law. Case-Laws Income Tax Tue, 11 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801047