https://www.taxtmi.com/caselaws?id=377518 The dominant issue was determination of the arm's length price (ALP) of royalty paid in an international transaction for use of trade name/trademarks, where the taxpayer applied CUP as the most appropriate method. The ITAT held that the benchmarking study lacked reliability due to inadequate product/technology comparability, non-availability of relevant third-party agreements and terms (including economic indicators and risk), absence of geographic adjustments, unjustified database selection, and inappropriate filters. On this legal and factual insufficiency, the ITAT remanded the matter on a limited basis to the TPO for fresh examination of comparables and ALP, directing the taxpayer to file a revised comparability analysis with justified databases, filters, and adjustments for AYs 2009-10 to 2012-13. en-us Mon, 25 Mar 2019 00:00:00 +0530 Fri, 19 Dec 2025 17:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=377518 The dominant issue was determination of the arm's length price (ALP) of royalty paid in an international transaction for use of trade name/trademarks, where the taxpayer applied CUP as the most appropriate method. The ITAT held that the benchmarking study lacked reliability due to inadequate product/technology comparability, non-availability of relevant third-party agreements and terms (including economic indicators and risk), absence of geographic adjustments, unjustified database selection, and inappropriate filters. On this legal and factual insufficiency, the ITAT remanded the matter on a limited basis to the TPO for fresh examination of comparables and ALP, directing the taxpayer to file a revised comparability analysis with justified databases, filters, and adjustments for AYs 2009-10 to 2012-13. Case-Laws Income Tax Mon, 25 Mar 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=377518