https://www.taxtmi.com/caselaws?id=334105 The High Court upheld the Income Tax Appellate Tribunal's decision to treat royalty and technical assistance fee as separate transactions for benchmarking. It emphasized the assessee's burden to prove arm's length transactions and upheld the rejection of the technical assistance fee explanation. Regarding the benchmarking method, the High Court ruled in favor of applying the Transactional Net Margin Method consistently, rejecting the selective use of the Comparable Uncontrolled Price method for the technical assistance fee. The case was remanded for a fresh determination of the arm's length price using TNMM across all transactions. en-us Tue, 25 Oct 2016 00:00:00 +0530 Tue, 31 Jan 2017 18:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=334105 The High Court upheld the Income Tax Appellate Tribunal's decision to treat royalty and technical assistance fee as separate transactions for benchmarking. It emphasized the assessee's burden to prove arm's length transactions and upheld the rejection of the technical assistance fee explanation. Regarding the benchmarking method, the High Court ruled in favor of applying the Transactional Net Margin Method consistently, rejecting the selective use of the Comparable Uncontrolled Price method for the technical assistance fee. The case was remanded for a fresh determination of the arm's length price using TNMM across all transactions. Case-Laws Income Tax Tue, 25 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=334105