https://www.taxtmi.com/caselaws?id=801338 Common shareholding of at least 26% voting power in each enterprise triggers associated-enterprise status under section 92A(2), supporting transfer-pricing scrutiny. Chapter X supplies a mechanism for computing the arm's-length value of international transactions; it does not create a separate charge of notional income, and section 92C requires a prescribed most appropriate method rather than ad hoc pricing. Capital scientific-research expenditure is deductible only when related to the taxpayer's own business, while unpaid leave encashment remains subject to the applicable payment condition. Software with an enduring benefit is capital, whereas one-year software may be revenue. Research expenditure intended to yield enduring benefit is capital even if research does not succeed. en-us Thu, 15 Oct 2026 00:00:00 +0530 Mon, 19 Oct 2026 07:01:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801338 Common shareholding of at least 26% voting power in each enterprise triggers associated-enterprise status under section 92A(2), supporting transfer-pricing scrutiny. Chapter X supplies a mechanism for computing the arm's-length value of international transactions; it does not create a separate charge of notional income, and section 92C requires a prescribed most appropriate method rather than ad hoc pricing. Capital scientific-research expenditure is deductible only when related to the taxpayer's own business, while unpaid leave encashment remains subject to the applicable payment condition. Software with an enduring benefit is capital, whereas one-year software may be revenue. Research expenditure intended to yield enduring benefit is capital even if research does not succeed. Case-Laws Income Tax Thu, 15 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801338