https://www.taxtmi.com/caselaws?id=390323 The dominant issue was whether payment of shared service charges could be aggregated with manufacturing-related international transactions under TNMM. The Tribunal held aggregation impermissible because the services were not shown to be closely linked to manufacturing and, in any event, the taxpayer failed to prove actual receipt of services or substantiate the cost-sharing arrangement; the TP disallowance was therefore upheld and the additional ground dismissed. On trademark/royalty payments, the Tribunal held the TPO erred in disallowing the incremental 0.5% by treating it as unnecessary; the ALP had to be determined for the combined royalty transaction at 4.5%. The matter was set aside and remanded to the AO/TPO for fresh ALP determination. en-us Fri, 20 Dec 2019 00:00:00 +0530 Thu, 08 Jan 2026 12:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=390323 The dominant issue was whether payment of shared service charges could be aggregated with manufacturing-related international transactions under TNMM. The Tribunal held aggregation impermissible because the services were not shown to be closely linked to manufacturing and, in any event, the taxpayer failed to prove actual receipt of services or substantiate the cost-sharing arrangement; the TP disallowance was therefore upheld and the additional ground dismissed. On trademark/royalty payments, the Tribunal held the TPO erred in disallowing the incremental 0.5% by treating it as unnecessary; the ALP had to be determined for the combined royalty transaction at 4.5%. The matter was set aside and remanded to the AO/TPO for fresh ALP determination. Case-Laws Income Tax Fri, 20 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=390323