Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
A unilateral advance pricing agreement fixing a consolidated 1.9% of net sales for royalty and fees for technical services was treated as highly persuasive guidance for comparability analysis where the transactions were similar. On that basis, the royalty and technical fee adjustment was found excessive, and the Assessing Officer was directed to cap the rate at 1.9% of net sales in line with the CBDT-accepted APA. The remaining grounds were left open or treated as consequential.
A unilateral advance pricing agreement fixing a consolidated 1.9% of net sales for royalty and fees for technical services was treated as highly persuasive guidance for comparability analysis where the transactions were similar. On that basis, the royalty and technical fee adjustment was found excessive, and the Assessing Officer was directed to cap the rate at 1.9% of net sales in line with the CBDT-accepted APA. The remaining grounds were left open or treated as consequential.
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