https://www.taxtmi.com/caselaws?id=393637 The Tribunal partially allowed the assessee's appeal, ruling that distribution fees were not to be characterized as Royalty. The Transfer Pricing Officer's adjustment was rejected, and the Tribunal upheld the assessee's economic analysis using the TNMM. The Tribunal directed reconsideration of comparables, verification of TDS and MAT credit claims, and recalculation of Transfer Pricing adjustment and interest under Section 234B. Penalty proceedings under Section 271(1)(c) were deemed premature. The decision stressed adherence to legal principles and proper benchmarking in Transfer Pricing cases. en-us Fri, 13 Mar 2020 00:00:00 +0530 Tue, 03 Nov 2020 16:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=393637 The Tribunal partially allowed the assessee's appeal, ruling that distribution fees were not to be characterized as Royalty. The Transfer Pricing Officer's adjustment was rejected, and the Tribunal upheld the assessee's economic analysis using the TNMM. The Tribunal directed reconsideration of comparables, verification of TDS and MAT credit claims, and recalculation of Transfer Pricing adjustment and interest under Section 234B. Penalty proceedings under Section 271(1)(c) were deemed premature. The decision stressed adherence to legal principles and proper benchmarking in Transfer Pricing cases. Case-Laws Income Tax Fri, 13 Mar 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=393637