https://www.taxtmi.com/caselaws?id=239753 The ITAT Mumbai upheld the assessee's transfer pricing methodology, rejecting the Revenue's adjustments that included non-AE transactions in AE margins, which violated Rule 10B(1)(e). The tribunal accepted the TPO's 25% related party transaction filter for comparables and denied the grant of a standard ±5% deduction as per the Finance Act, 2012, ruling that the AO's refusal to allow it was lawful. Regarding royalty payments under a collaboration agreement, the tribunal held that payments approved or deemed approved by RBI must be accepted at arm's length price, rejecting the TPO's full disallowance. The decision favored the assessee on both transfer pricing adjustments and royalty disallowance. en-us Wed, 27 Feb 2013 00:00:00 +0530 Mon, 04 Aug 2025 16:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239753 The ITAT Mumbai upheld the assessee's transfer pricing methodology, rejecting the Revenue's adjustments that included non-AE transactions in AE margins, which violated Rule 10B(1)(e). The tribunal accepted the TPO's 25% related party transaction filter for comparables and denied the grant of a standard ±5% deduction as per the Finance Act, 2012, ruling that the AO's refusal to allow it was lawful. Regarding royalty payments under a collaboration agreement, the tribunal held that payments approved or deemed approved by RBI must be accepted at arm's length price, rejecting the TPO's full disallowance. The decision favored the assessee on both transfer pricing adjustments and royalty disallowance. Case-Laws Income Tax Wed, 27 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239753