Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
TP adjustment - ALP of royalty - In the absence of empirical data, stating higher royalty was not justified only because it did not result in any tangible benefit to the Assessee was not be the right approach - ITAT direction to the TPO to adopt the percentage(5.6%) as has been accepted by DRP based on survey report of travel industry in subsequent year does not appear to be unreasonable - no substantial question of law arises
TP adjustment - ALP of royalty - In the absence of empirical data, stating higher royalty was not justified only because it did not result in any tangible benefit to the Assessee was not be the right approach - ITAT direction to the TPO to adopt the percentage(5.6%) as has been accepted by DRP based on survey report of travel industry in subsequent year does not appear to be unreasonable - no substantial question of law arises
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