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        Case ID :
        Income Tax

        The ITAT held that the arm's length price of salary paid to...

        ITAT Upholds Arm's Length Salary Pricing for Global Sales Staff Under TNMM Method, Deletes TPO Adjustment

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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.
                                The ITAT held that the arm's length price of salary paid to global sales personnel, being intrinsically linked to software product sales to the AE and benchmarked via the TNMM method accepted by the TPO, should not be separately adjusted. Consequently, the TPO's downward TP adjustment on the salary cross-charge was deleted. Regarding the adjustment under section 143(1), the tribunal noted the pending rectification application and appeal filed by the assessee, directing the AO and FAA to dispose of both expeditiously. The order thus restores the salary payment treatment within the overall TNMM benchmarking and mandates prompt adjudication of related procedural matters.
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