https://www.taxtmi.com/caselaws?id=436953 The Tribunal allowed the appeal of the assessee, directing the deletion of both the transfer pricing adjustment and the disallowance of the royalty payment. The Tribunal upheld the use of segmented information for benchmarking international transactions, rejected the rejection of audited segmental accounts, and found errors in the functional analysis and comparables used by the TPO and DRP. The Tribunal emphasized the revenue nature of the royalty payment and the lack of enduring advantage or creation of a capital asset, leading to the deletion of the disallowance. en-us Wed, 04 Jan 2023 00:00:00 +0530 Mon, 24 Apr 2023 18:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436953 The Tribunal allowed the appeal of the assessee, directing the deletion of both the transfer pricing adjustment and the disallowance of the royalty payment. The Tribunal upheld the use of segmented information for benchmarking international transactions, rejected the rejection of audited segmental accounts, and found errors in the functional analysis and comparables used by the TPO and DRP. The Tribunal emphasized the revenue nature of the royalty payment and the lack of enduring advantage or creation of a capital asset, leading to the deletion of the disallowance. Case-Laws Income Tax Wed, 04 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436953