https://www.taxtmi.com/caselaws?id=426272 The Tribunal allowed the appellant's appeal partly, directing the AO/TPO to re-compute operating margins and make adjustments. The Tribunal emphasized considering the business model and transaction nature in benchmarking international transactions and determining the arm's length price. Transfer pricing adjustments were made, including rejecting the combined transaction approach, inappropriate comparable companies, and RPM method application. Corporate tax adjustments disallowed royalty and homologation expenditure, later allowed as revenue expenditure. The Tribunal's decision highlighted the importance of accurate benchmarking and considering transaction specifics. en-us Fri, 15 Jul 2022 00:00:00 +0530 Fri, 12 Aug 2022 08:29:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=426272 The Tribunal allowed the appellant's appeal partly, directing the AO/TPO to re-compute operating margins and make adjustments. The Tribunal emphasized considering the business model and transaction nature in benchmarking international transactions and determining the arm's length price. Transfer pricing adjustments were made, including rejecting the combined transaction approach, inappropriate comparable companies, and RPM method application. Corporate tax adjustments disallowed royalty and homologation expenditure, later allowed as revenue expenditure. The Tribunal's decision highlighted the importance of accurate benchmarking and considering transaction specifics. Case-Laws Income Tax Fri, 15 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=426272