https://www.taxtmi.com/caselaws?id=262693 The Tribunal dismissed the Revenue's appeal, upholding the DRP's decision to delete the ALP adjustments proposed by the AO. It was held that the payments of royalty and technical fees were justified, at arm's length, and made as per agreements approved by the RBI and the Ministry of Industries. The Tribunal emphasized that the TPO should focus on determining the ALP based on comparable transactions and not question the business decisions of the assessee. The decision of the Tribunal in the assessee's own case for earlier A.Ys was applied to the current A.Y, leading to the dismissal of the Revenue's appeal. en-us Fri, 07 Aug 2015 00:00:00 +0530 Tue, 18 Aug 2015 06:48:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=262693 The Tribunal dismissed the Revenue's appeal, upholding the DRP's decision to delete the ALP adjustments proposed by the AO. It was held that the payments of royalty and technical fees were justified, at arm's length, and made as per agreements approved by the RBI and the Ministry of Industries. The Tribunal emphasized that the TPO should focus on determining the ALP based on comparable transactions and not question the business decisions of the assessee. The decision of the Tribunal in the assessee's own case for earlier A.Ys was applied to the current A.Y, leading to the dismissal of the Revenue's appeal. Case-Laws Income Tax Fri, 07 Aug 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=262693