https://www.taxtmi.com/caselaws?id=329296 The Tribunal held that the segregation of international transactions for transfer pricing, specifically the payment of Royalty and Fees for Technical Services (FTS), was justified. It emphasized the need to benchmark these transactions separately and rejected the use of RBI-approved rates for determining the Arm's Length Price (ALP). The Tribunal favored the Comparable Uncontrolled Price (CUP) method for determining the ALP, criticizing the incorrect approach of the Transfer Pricing Officer (TPO) in comparing expenses to sales ratios. The matter was remitted for fresh determination of ALP, with directions to allow the tax credit claimed by the assessee. en-us Fri, 29 Apr 2016 00:00:00 +0530 Tue, 28 Jun 2016 05:05:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=329296 The Tribunal held that the segregation of international transactions for transfer pricing, specifically the payment of Royalty and Fees for Technical Services (FTS), was justified. It emphasized the need to benchmark these transactions separately and rejected the use of RBI-approved rates for determining the Arm's Length Price (ALP). The Tribunal favored the Comparable Uncontrolled Price (CUP) method for determining the ALP, criticizing the incorrect approach of the Transfer Pricing Officer (TPO) in comparing expenses to sales ratios. The matter was remitted for fresh determination of ALP, with directions to allow the tax credit claimed by the assessee. Case-Laws Income Tax Fri, 29 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=329296