https://www.taxtmi.com/caselaws?id=276112 The Tribunal upheld the use of the Transactional Net Margin Method (TNMM) over the Comparable Uncontrolled Price (CUP) method for evaluating royalty payments. Consistency in benchmarking methods was emphasized, leading to the rejection of the CUP method. The deletion of homologation expenses addition was upheld, citing the Assessing Officer's failure to examine details. The issue of expenditure on capitalized cars was remitted for re-examination. The Department's appeals on transfer pricing adjustments for royalty payments were dismissed, while the cross objection by the assessee was allowed for statistical purposes. en-us Wed, 21 Mar 2018 00:00:00 +0530 Tue, 30 Oct 2018 09:59:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276112 The Tribunal upheld the use of the Transactional Net Margin Method (TNMM) over the Comparable Uncontrolled Price (CUP) method for evaluating royalty payments. Consistency in benchmarking methods was emphasized, leading to the rejection of the CUP method. The deletion of homologation expenses addition was upheld, citing the Assessing Officer's failure to examine details. The issue of expenditure on capitalized cars was remitted for re-examination. The Department's appeals on transfer pricing adjustments for royalty payments were dismissed, while the cross objection by the assessee was allowed for statistical purposes. Case-Laws Income Tax Wed, 21 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276112