https://www.taxtmi.com/caselaws?id=383227 The Tribunal upheld the deletion of the transfer pricing adjustment for royalty payments made by an Indian company to its overseas Associated Enterprise. The Tribunal found that the Transfer Pricing Officer did not apply a prescribed method in determining the arm's length price, leading to an ad-hoc decision that was legally unsustainable. The decision was based on the compliance with statutory regulations, prolonged negotiations between joint venture partners, and consistency with payments made by other group entities. The Revenue's appeal was dismissed, and the decision applied to assessment years 2004-05 and 2005-06. en-us Thu, 25 Apr 2019 00:00:00 +0530 Thu, 18 Jul 2019 18:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=383227 The Tribunal upheld the deletion of the transfer pricing adjustment for royalty payments made by an Indian company to its overseas Associated Enterprise. The Tribunal found that the Transfer Pricing Officer did not apply a prescribed method in determining the arm's length price, leading to an ad-hoc decision that was legally unsustainable. The decision was based on the compliance with statutory regulations, prolonged negotiations between joint venture partners, and consistency with payments made by other group entities. The Revenue's appeal was dismissed, and the decision applied to assessment years 2004-05 and 2005-06. Case-Laws Income Tax Thu, 25 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=383227