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HC upheld ITAT's decision deleting transfer pricing adjustments related to expatriate salary reimbursements and royalty payments. The court rejected TPO's contention that ALP should be nil due to assessee's losses, emphasizing that business losses do not negate the value of services or technical know-how. For expatriate costs, court noted these were pure reimbursements without markup and were subsumed in commission earnings already found arm's length under TNMM. Regarding royalty, HC affirmed that technical know-how procurement was a commercial decision outside TPO's review scope. Revenue's allegation of double deduction was dismissed for lack of substantiation. The court found no basis to interfere with ITAT's conclusions on both issues.
HC upheld ITAT's decision deleting transfer pricing adjustments related to expatriate salary reimbursements and royalty payments. The court rejected TPO's contention that ALP should be nil due to assessee's losses, emphasizing that business losses do not negate the value of services or technical know-how. For expatriate costs, court noted these were pure reimbursements without markup and were subsumed in commission earnings already found arm's length under TNMM. Regarding royalty, HC affirmed that technical know-how procurement was a commercial decision outside TPO's review scope. Revenue's allegation of double deduction was dismissed for lack of substantiation. The court found no basis to interfere with ITAT's conclusions on both issues.
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