Principal Commissioner Of Income Tax vs M/S. Merck Ltd.

Whether the Tribunal was justified in granting 10% quality adjustment in ALP determination using CUP method --- Held Yes; Whether the Tribunal was justified in deleting adjustments for technical consultancy fees --- Held Yes; Whether share buyback expenditure is capital expenditure disallowable u/s 37 --- Held No; Whether sales promotion and conference expenses are disallowable for lack of benefit --- Held No; Whether Tribunal should have adjudicated disallowance of pre-amendment medical ethics expenses --- Held No