https://www.taxtmi.com/caselaws?id=208395 ITAT, Mumbai allowed the assessee's appeals, holding that the Transfer Pricing Officer (TPO) had exceeded his jurisdiction in determining the Arm's Length Price (ALP) of royalty payable to its associated enterprise at nil. The Tribunal held that bad debts written off in respect of software products sold in India cannot be a parameter for determining ALP under s. 92C read with Rule 10B of the I.T. Rules. As the TPO had applied an impermissible method not authorised by the statute, the resultant ALP determination was unsustainable. The AO was directed to accept the royalty ALP as declared by the assessee for both years. en-us Thu, 28 Jan 2010 00:00:00 +0530 Mon, 01 Dec 2025 15:35:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208395 ITAT, Mumbai allowed the assessee's appeals, holding that the Transfer Pricing Officer (TPO) had exceeded his jurisdiction in determining the Arm's Length Price (ALP) of royalty payable to its associated enterprise at nil. The Tribunal held that bad debts written off in respect of software products sold in India cannot be a parameter for determining ALP under s. 92C read with Rule 10B of the I.T. Rules. As the TPO had applied an impermissible method not authorised by the statute, the resultant ALP determination was unsustainable. The AO was directed to accept the royalty ALP as declared by the assessee for both years. Case-Laws Income Tax Thu, 28 Jan 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208395