https://www.taxtmi.com/caselaws?id=395272 The Tribunal allowed the assessee's appeal, directing the revenue to reassess the adjustments using TNMM as the most appropriate method, consider the evidence provided by the assessee, and grant necessary reliefs as per the Income Tax Act. The Tribunal found that the AO's adjustments were not justified, rejected the application of the benefit test and CUP method, and directed a reassessment of the Arm's Length Price for royalty and product development payments. Additionally, the Tribunal instructed the revenue to accept the commercial expediency of the expenditure, consider group companies' payments, and drop penalty proceedings under section 271(1)(c). en-us Tue, 05 May 2020 00:00:00 +0530 Thu, 14 May 2020 12:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=395272 The Tribunal allowed the assessee's appeal, directing the revenue to reassess the adjustments using TNMM as the most appropriate method, consider the evidence provided by the assessee, and grant necessary reliefs as per the Income Tax Act. The Tribunal found that the AO's adjustments were not justified, rejected the application of the benefit test and CUP method, and directed a reassessment of the Arm's Length Price for royalty and product development payments. Additionally, the Tribunal instructed the revenue to accept the commercial expediency of the expenditure, consider group companies' payments, and drop penalty proceedings under section 271(1)(c). Case-Laws Income Tax Tue, 05 May 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=395272