Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from exempt-income calculations.

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....Transfer-pricing treatment of corporate guarantees and interest on convertible loans followed consistent prior-year treatment where no factual difference was shown. Payments to non-residents, product, trademark and patent registration expenses, in-house research and development deductions, vehicle depreciation, and partner remuneration were also addressed through established prior-year positions. Exempt-income expenditure disallowance is computed only by reference to investments yielding exempt income; foreign investments generating taxable dividends require exclusion, subject to verification. Foreign-currency royalty receipts already recorded and offered to tax cannot be treated as undisclosed income without supporting material. Employee contributions already disallowed by the taxpayer cannot be disallowed again.....