https://www.taxtmi.com/caselaws?id=341938 The ITAT PUNE ruled in favor of the assessee on multiple transfer pricing issues. The tribunal held that companies dissimilar in functionality should be deselected from comparable analysis and directed the AO to adopt corrected profit level indicators. Management fees were allowed as business expenditure where commercial expediency was established, following SC precedent. Royalty payments at 2.85% to associate enterprises were deemed at arm's length rate as they were RBI/SIA approved. The tribunal noted TPO exceeded jurisdiction by determining benefit derivation rather than focusing solely on arm's length pricing benchmarking. en-us Fri, 10 Feb 2017 00:00:00 +0530 Mon, 12 May 2025 15:47:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=341938 The ITAT PUNE ruled in favor of the assessee on multiple transfer pricing issues. The tribunal held that companies dissimilar in functionality should be deselected from comparable analysis and directed the AO to adopt corrected profit level indicators. Management fees were allowed as business expenditure where commercial expediency was established, following SC precedent. Royalty payments at 2.85% to associate enterprises were deemed at arm's length rate as they were RBI/SIA approved. The tribunal noted TPO exceeded jurisdiction by determining benefit derivation rather than focusing solely on arm's length pricing benchmarking. Case-Laws Income Tax Fri, 10 Feb 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=341938