https://www.taxtmi.com/caselaws?id=437502 Royalty payment for technical support was treated as an international transaction under s.92B, and the issue was whether it could be aggregated with other manufacturing-segment transactions for ALP determination. Relying on the co-ordinate bench ruling in the taxpayer's own case and applying judicial consistency, the Tribunal held that the royalty transaction cannot be clubbed with the manufacturing segment; the AO/TPO was directed to recompute the adjustment in accordance with law after affording effective hearing, and the ground was allowed for statistical purposes. On addition of duty drawback, since the taxpayer asserted it was taxed in the subsequent year on actual receipt, the matter was remanded to the AO for verification to prevent double taxation. en-us Fri, 17 Feb 2023 00:00:00 +0530 Thu, 08 Jan 2026 12:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437502 Royalty payment for technical support was treated as an international transaction under s.92B, and the issue was whether it could be aggregated with other manufacturing-segment transactions for ALP determination. Relying on the co-ordinate bench ruling in the taxpayer's own case and applying judicial consistency, the Tribunal held that the royalty transaction cannot be clubbed with the manufacturing segment; the AO/TPO was directed to recompute the adjustment in accordance with law after affording effective hearing, and the ground was allowed for statistical purposes. On addition of duty drawback, since the taxpayer asserted it was taxed in the subsequent year on actual receipt, the matter was remanded to the AO for verification to prevent double taxation. Case-Laws Income Tax Fri, 17 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437502