https://www.taxtmi.com/caselaws?id=402646 The ITAT set aside the CIT(A)'s orders on transfer pricing adjustments for royalty payments and re-computation of deduction u/s 10A. It directed the issues to be reconsidered by the AO/TPO in accordance with prior directives, emphasizing the need for fair opportunity for the assessee to present their case and proper consideration of jurisdictional aspects. The ITAT highlighted that if no comparables were found for royalty payments, they should be considered part of international transactions under the trading segment. The CIT(A) failed to consider the ITAT's directions, leading to the orders being set aside for proper examination. en-us Thu, 07 Jan 2021 00:00:00 +0530 Fri, 08 Jan 2021 10:20:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=402646 The ITAT set aside the CIT(A)'s orders on transfer pricing adjustments for royalty payments and re-computation of deduction u/s 10A. It directed the issues to be reconsidered by the AO/TPO in accordance with prior directives, emphasizing the need for fair opportunity for the assessee to present their case and proper consideration of jurisdictional aspects. The ITAT highlighted that if no comparables were found for royalty payments, they should be considered part of international transactions under the trading segment. The CIT(A) failed to consider the ITAT's directions, leading to the orders being set aside for proper examination. Case-Laws Income Tax Thu, 07 Jan 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=402646