https://www.taxtmi.com/caselaws?id=295544 The Tribunal allowed the appeal of the assessee, directing the deletion of both the capital expenditure addition and the transfer pricing adjustment. The Tribunal found that the payment made for licensing software should be considered a revenue expenditure, not an intangible asset. Additionally, the Tribunal concluded that the apportionment of the management fee aligned with the Arm's Length Price in respective segments, leading to no adjustment needed for intra-group services. en-us Fri, 15 Mar 2019 00:00:00 +0530 Wed, 09 Jun 2021 09:24:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=295544 The Tribunal allowed the appeal of the assessee, directing the deletion of both the capital expenditure addition and the transfer pricing adjustment. The Tribunal found that the payment made for licensing software should be considered a revenue expenditure, not an intangible asset. Additionally, the Tribunal concluded that the apportionment of the management fee aligned with the Arm's Length Price in respective segments, leading to no adjustment needed for intra-group services. Case-Laws Income Tax Fri, 15 Mar 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=295544