Cost-to-cost reimbursements exclude value-free third-party expenses from transfer-pricing adjustment, while unsupported salary cross-charges remain adjusted.

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....Cost-to-cost reimbursements of third-party marketing, promotion, travel and other expenses involving no services or value addition do not warrant an upward transfer-pricing adjustment; domestic-group recoveries require verification. Salary and wage cross-charges from foreign associated enterprises remain subject to adjustment where shared employee services are insufficiently substantiated. Television-channel distribution licence fees should be benchmarked under the Comparable Uncontrolled Price method where comparable licence agreements exist; software and IT distributors are not functionally comparable. A foreign-tax deduction claim not made in the return may be raised before appellate authorities, but requires factual verification where tax credit was unavailable or unclaimed.....