https://www.taxtmi.com/caselaws?id=427942 The court upheld the deletion of transfer pricing adjustments for royalty payments, rejecting the appellant's challenge to the ITAT order. It found that the TPO's rejection of comparables lacked proper reasoning and was based on conjectures, emphasizing the need for a comprehensive analysis. The court emphasized that comparables should not be excluded solely based on high royalty rates and highlighted the importance of considering various factors in transfer pricing adjustments. Ultimately, the appeal was dismissed as no substantial legal questions were identified, underscoring the significance of thorough analysis in transfer pricing matters. en-us Thu, 08 Sep 2022 00:00:00 +0530 Mon, 14 Aug 2023 14:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=427942 The court upheld the deletion of transfer pricing adjustments for royalty payments, rejecting the appellant's challenge to the ITAT order. It found that the TPO's rejection of comparables lacked proper reasoning and was based on conjectures, emphasizing the need for a comprehensive analysis. The court emphasized that comparables should not be excluded solely based on high royalty rates and highlighted the importance of considering various factors in transfer pricing adjustments. Ultimately, the appeal was dismissed as no substantial legal questions were identified, underscoring the significance of thorough analysis in transfer pricing matters. Case-Laws Income Tax Thu, 08 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=427942