Businessman's perspective governs managerial remuneration; rupee debenture interest benchmarks to Prime Lending Rate for arm's length testing.

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....Employee benefit expenses were not to be disallowed merely because managerial remuneration increased while revenue declined, where the expenditure was genuine, business-related and supported by material showing services rendered. The reasonableness of remuneration had to be judged from the businessman's perspective, not on the Assessing Officer's subjective view, and the Rule 46A objection failed because the relied-on documents were not treated as additional evidence requiring remand. On transfer pricing, interest on rupee-denominated non-convertible debentures was benchmarked against the Prime Lending Rate, not EBLR; on that basis the coupon rate was treated as arm's length and the adjustment was deleted.....