https://www.taxtmi.com/caselaws?id=206929 The tribunal partly allowed the appeal, directing the Assessing Officer to allocate 80% of the total receipts by the associated enterprise (AE) to the assessee for international transactions. This adjustment aimed to align compensation with the value contributed by the assessee, recognizing the unique intangibles and functions performed. The decision emphasized a fair distribution of compensation based on the critical functions and intangibles developed by the assessee, ensuring a more equitable outcome in line with Transfer Pricing regulations. en-us Fri, 30 Sep 2011 00:00:00 +0530 Wed, 05 Jun 2013 14:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=206929 The tribunal partly allowed the appeal, directing the Assessing Officer to allocate 80% of the total receipts by the associated enterprise (AE) to the assessee for international transactions. This adjustment aimed to align compensation with the value contributed by the assessee, recognizing the unique intangibles and functions performed. The decision emphasized a fair distribution of compensation based on the critical functions and intangibles developed by the assessee, ensuring a more equitable outcome in line with Transfer Pricing regulations. Case-Laws Income Tax Fri, 30 Sep 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=206929