Employee gain-sharing incentive payouts and ITES transfer-pricing comparables; payments allowed u/s43B(c), cost reallocation addition deleted

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....Incentive payments to employees under an executive gain-sharing plan were held to be additional remuneration in the nature of bonus/incentive, not severance compensation; since the liability crystallised during the year and the unpaid portion was discharged before the return-filing due date, the expenditure was allowable under s. 43B(c) read with the first proviso, and the disallowance was deleted. For transfer pricing of an ITES provider, a high-end KPO company and a professional/accounting advisory company were excluded due to functional dissimilarity and inadequate data, while several routine ITES/BPO comparables were included based on functional similarity, availability of segmental/quarterly data, and consistency with prior years. For .........