The assessee, engaged in the manufacture and sale of motorcycles and scooters, paid export commission and royalty to its associated enterprises. The Transfer Pricing Officer determined the arm’s length price of both transactions to be nil. Following earlier orders in the assessee’s own case, the Tribunal held that the assessee had established commercial expediency and higher profitability from exports, and therefore the export commission adjustment was unsustainable. Royalty paid under the technical know-how agreement was held to be revenue expenditure and allowable. Expenditure incurred on glow signboards, signage, sales tools and dealer fixtures was also held to be revenue expenditure. However, the deduction of education cess was rejected in view of the retrospective amendment to section 40(a)(ii). The claims relating to excess dividend distribution tax and technical know-how expenditure, not having been made in the original or revised return, were restored to the Assessing Officer for fresh adjudication. (AY. 2018-19)