https://www.taxtmi.com/caselaws?id=352665 The High Court upheld the findings of the ITAT, dismissing the appeal regarding the attribution of income based on international transactions under Section 92B. The Court supported the adjustments made by the TPO in computing royalty rates, considering the evolution of the agreement and changes in shareholding. Additionally, the Court affirmed the determination of the arm's length price for royalty payments, emphasizing the unique circumstances of the case and the lack of comparables. Transfer pricing adjustments under Section 92C were deemed applicable, highlighting the need for thorough analysis in such cases. The treatment of Dabur brand usage as an international transaction was also upheld, concluding the dispute. en-us Wed, 13 Dec 2017 00:00:00 +0530 Tue, 19 Dec 2017 08:51:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=352665 The High Court upheld the findings of the ITAT, dismissing the appeal regarding the attribution of income based on international transactions under Section 92B. The Court supported the adjustments made by the TPO in computing royalty rates, considering the evolution of the agreement and changes in shareholding. Additionally, the Court affirmed the determination of the arm's length price for royalty payments, emphasizing the unique circumstances of the case and the lack of comparables. Transfer pricing adjustments under Section 92C were deemed applicable, highlighting the need for thorough analysis in such cases. The treatment of Dabur brand usage as an international transaction was also upheld, concluding the dispute. Case-Laws Income Tax Wed, 13 Dec 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=352665