https://www.taxtmi.com/caselaws?id=306217 The Tribunal allowed the appeals for statistical purposes and remanded the matters back to the Taxation Officer (TPO)/Assessing Officer for fresh determination based on the Tribunal's directions. The TPO's characterization of payments under a Cost Sharing Agreement as Intra-Group Services and determination of arm's length price at 'Nil' was set aside. The Tribunal emphasized the importance of comparing prices directly in controlled and uncontrolled transactions and directed a fresh determination under the Comparable Uncontrolled Price (CUP) method or any other appropriate method if CUP was not feasible. en-us Fri, 27 Nov 2020 00:00:00 +0530 Tue, 17 Jan 2023 20:53:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306217 The Tribunal allowed the appeals for statistical purposes and remanded the matters back to the Taxation Officer (TPO)/Assessing Officer for fresh determination based on the Tribunal's directions. The TPO's characterization of payments under a Cost Sharing Agreement as Intra-Group Services and determination of arm's length price at 'Nil' was set aside. The Tribunal emphasized the importance of comparing prices directly in controlled and uncontrolled transactions and directed a fresh determination under the Comparable Uncontrolled Price (CUP) method or any other appropriate method if CUP was not feasible. Case-Laws Income Tax Fri, 27 Nov 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306217