Transfer pricing disputes concerned reimbursements of personnel...

Transfer pricing disputes concerned reimbursements of personnel cost, IT-related expenses, advertisement and publicity expenses, and royalty. The Tribunal upheld deletion of adjustments on personnel cost and IT-related reimbursements because the assessee showed they were pure cost-to-cost items, with supporting material and no markup; the personnel-cost issue was also covered by the assessee's earlier years' orders. The Tribunal sustained the adjustment on advertisement and publicity reimbursement because the assessee failed to produce documentary evidence establishing the need for and incurrence of the . The royalty adjustment was deleted on consistency, the issue being covered by the assessee's own earlier order.

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