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1. Royalty Benchmarking - assessee had adopted TNMM at the entity level in which process royalty payment is considered as closely linked transaction and part of operating...

2. Nature of expenses - payment of royalty - acquisition of intangible asset - the appellate authorities, while deleting the disallowances made by the assessing officer,...

3. Accrual of income in India - PE in India or not? - use or right to use brand name/trade mark - the receipts cannot be treated as royalty under Article 12(3)(a) of the...

4. Royalty payment to FCC Co. Ltd., Japan - revenue or capital expenditure - Either having 50% control or 100% control that will not change the colour of nature of...

5. Royalty payment - revenue expenditure or capital expenditure - payment is purely revenue in nature, as they provide for payment of license fee for manufacture and sale...

6. Disallowance of expenditure as capital expenditure being 25% of royalty amount paid - it cannot be said that the Sweden Company had relinquished its command over the...

7. Disallowance of cash payments in excess of prescribed limit u/s. 40A(3) - even though few payments is covered u/s. 40A(3) of the Act, because of peculiar nature of...

8. Disallowance of royalty expenses - allowable revenue expenses - It is only in Assessment Year 2005-06, the said payment of royalty has not been allowed in the hands of...

9. Disallowance of freight expenditure u/s 40A(3) paid in Cash - As enhanced limit of ₹ 35,000/- is applicable for the payment to the transport operators and in other...

10. Addition u/s 40A(3) - expenditure paid at various project sites in cash mode - unexplained expenditure - We invoke stricter interpretation of the impugned disallowance...

11. Income accrued in India - consideration received by the assessee for sale of software cannot be treated as royalty under the provision of section 9(1)(vi) of the Act as...

12. Disallowance u/s 40A(3) - Cash payment - Section 40A(3) is not applicable when the net profit rate was applied by the AO and once a net profit rate is applied the...

13. Disallowance u/s 40A(3) - transactions and payments made in cash - assessee filed affidavits from sub-contractors of assessee firm and they insisted for cash payments to...

14. Nature of expenditure - Revenue expenditure u/s 37(1) or capital expenditure - royalty payment for user of technical know-how and intellectual property rights along with...

15. TP Adjustment - PLI computation - if rental expenditure is considered as an operating expenditure, then the reimbursement should be set off against the rental...