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    <title>Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and transfer-pricing principles.</title>
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    <description>Contingency expenses reflected in CTC reports could not be disallowed where they matched the regular books, the books were not rejected, and no evidence showed inflation or fictitious claims; deletion was sustained under the rule of consistency. No disallowance of expenditure relating to exempt income was sustainable because no income exempt under Chapter III was earned; deletion under section 14A read with Rule 8D was sustained. The royalty transfer-pricing adjustment was unsustainable because no prescribed method or proper benchmarking had been applied and relevant joint-venture and support-service documents were not properly considered; deletion was sustained. The Revenue&#039;s appeal was dismissed, while the cross-objection was infructuous.</description>
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    <pubDate>Wed, 21 Oct 2026 08:37:56 +0530</pubDate>
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      <title>Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and transfer-pricing principles.</title>
      <link>https://www.taxtmi.com/highlights?id=105208</link>
      <description>Contingency expenses reflected in CTC reports could not be disallowed where they matched the regular books, the books were not rejected, and no evidence showed inflation or fictitious claims; deletion was sustained under the rule of consistency. No disallowance of expenditure relating to exempt income was sustainable because no income exempt under Chapter III was earned; deletion under section 14A read with Rule 8D was sustained. The royalty transfer-pricing adjustment was unsustainable because no prescribed method or proper benchmarking had been applied and relevant joint-venture and support-service documents were not properly considered; deletion was sustained. The Revenue&#039;s appeal was dismissed, while the cross-objection was infructuous.</description>
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      <pubDate>Wed, 21 Oct 2026 08:37:56 +0530</pubDate>
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