https://www.taxtmi.com/caselaws?id=361014 The Tribunal allowed both appeals, setting aside the Assessing Officer's orders on two main issues. Firstly, regarding the Transfer Pricing adjustment made to the license fee paid by the assessee, the Tribunal directed a fresh examination by the Transfer Pricing Officer (TPO), emphasizing the need for a comprehensive approach. Secondly, concerning the disallowance under section 40(a)(ia) of the Act for A.Y. 2012-13, the Tribunal ruled in favor of the assessee, highlighting the compensatory nature of the payments to non-residents and the lack of permanent establishment in India, leading to the deletion of the disallowance. en-us Tue, 22 May 2018 00:00:00 +0530 Mon, 28 May 2018 08:38:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=361014 The Tribunal allowed both appeals, setting aside the Assessing Officer's orders on two main issues. Firstly, regarding the Transfer Pricing adjustment made to the license fee paid by the assessee, the Tribunal directed a fresh examination by the Transfer Pricing Officer (TPO), emphasizing the need for a comprehensive approach. Secondly, concerning the disallowance under section 40(a)(ia) of the Act for A.Y. 2012-13, the Tribunal ruled in favor of the assessee, highlighting the compensatory nature of the payments to non-residents and the lack of permanent establishment in India, leading to the deletion of the disallowance. Case-Laws Income Tax Tue, 22 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=361014