https://www.taxtmi.com/caselaws?id=355667 The Tribunal allowed the appeal filed by the taxpayer, directing the AO to delete the ALP adjustment on account of royalty payment and to provide full credit for taxes paid as claimed in the return of income. The Tribunal also held that the initiation of penalty proceedings was not justified. The Tribunal's decision was based on the consistent application of the TNMM as the MAM and adherence to the decisions of higher appellate authorities in the taxpayer's own case. en-us Fri, 09 Feb 2018 00:00:00 +0530 Fri, 16 Feb 2018 07:17:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=355667 The Tribunal allowed the appeal filed by the taxpayer, directing the AO to delete the ALP adjustment on account of royalty payment and to provide full credit for taxes paid as claimed in the return of income. The Tribunal also held that the initiation of penalty proceedings was not justified. The Tribunal's decision was based on the consistent application of the TNMM as the MAM and adherence to the decisions of higher appellate authorities in the taxpayer's own case. Case-Laws Income Tax Fri, 09 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=355667