https://www.taxtmi.com/caselaws?id=304014 TNMM was accepted as the most appropriate transfer pricing method for royalty paid for technical know-how, because the record did not show the unique intangibles or highly integrated joint contributions needed to justify a separate profit split method; the royalty adjustment was deleted. Reimbursement of salary for seconded employees was treated as a salary cost borne by the Indian entity, not fees for technical services, where the personnel worked under its control and the payment contained no income element; no withholding disallowance survived. Plant layout charges and advance tax credit claims were left for verification by the assessing authority. en-us Wed, 13 Apr 2022 00:00:00 +0530 Mon, 11 Aug 2025 18:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=304014 TNMM was accepted as the most appropriate transfer pricing method for royalty paid for technical know-how, because the record did not show the unique intangibles or highly integrated joint contributions needed to justify a separate profit split method; the royalty adjustment was deleted. Reimbursement of salary for seconded employees was treated as a salary cost borne by the Indian entity, not fees for technical services, where the personnel worked under its control and the payment contained no income element; no withholding disallowance survived. Plant layout charges and advance tax credit claims were left for verification by the assessing authority. Case-Laws Income Tax Wed, 13 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=304014