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        Case ID :
        Income Tax

        ITAT addressed transfer pricing adjustment concerning royalty...

        Transfer Pricing Adjustment: TPO Must Apply APA Parameters for Non-UK Entity Royalty Payments, Same as UK Entities

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                ITAT addressed transfer pricing adjustment concerning royalty payments for licensed manufacturing between appellant and non-UK entities. The tribunal determined that TPO's approach lacked objectivity in differentiating between UK and non-UK AEs, particularly given prior MAP proceedings accepting 4-5% compensation for AY 2013-14 and APA for AY 2018-19 to 2022-23. While MAP/APA decisions lack precedential value for different assessees, they carry significant persuasive weight for the same assessee. Applying consistency principles in tax matters, ITAT directed TPO to accept APA parameters for determining ALP of disputed transactions with non-UK AEs, effectively aligning treatment of royalty payments across jurisdictions.
                                Note: It is a system-generated summary and is for quick reference only.
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