https://www.taxtmi.com/caselaws?id=252326 The Tribunal allowed the assessee's appeal, directing the TPO to adopt a combined transaction approach for determining the arm's length price (ALP) and to identify suitable comparables for royalty payments. It emphasized that the TPO cannot set the ALP at NIL based on perceived lack of economic benefit and must use recognized methods under the Act. The Tribunal found the TPO's determinations unsustainable, requiring proper evaluation of technology support and related intangibles received by the assessee. en-us Fri, 11 Jul 2014 00:00:00 +0530 Fri, 13 Mar 2015 14:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252326 The Tribunal allowed the assessee's appeal, directing the TPO to adopt a combined transaction approach for determining the arm's length price (ALP) and to identify suitable comparables for royalty payments. It emphasized that the TPO cannot set the ALP at NIL based on perceived lack of economic benefit and must use recognized methods under the Act. The Tribunal found the TPO's determinations unsustainable, requiring proper evaluation of technology support and related intangibles received by the assessee. Case-Laws Income Tax Fri, 11 Jul 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252326