https://www.taxtmi.com/caselaws?id=443115 The Tribunal ruled in favor of the assessee, holding that the Transfer Pricing (TP) order passed by the Transfer Pricing Officer (TPO) beyond the prescribed limitation period was invalid. The addition of a 15% mark-up on reimbursement of expenses for registration of Patents and Trademark was deemed erroneous as it did not follow the prescribed method for determining the Arm's Length Price (ALP). The inclusion of Rs. 1,81,61,306/- as 'Fees for Technical Services' was set aside for fresh consideration by the Assessing Officer. The appeal was allowed partly for statistical purposes, with certain grounds becoming infructuous. en-us Wed, 31 May 2023 00:00:00 +0530 Sat, 16 Sep 2023 08:47:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443115 The Tribunal ruled in favor of the assessee, holding that the Transfer Pricing (TP) order passed by the Transfer Pricing Officer (TPO) beyond the prescribed limitation period was invalid. The addition of a 15% mark-up on reimbursement of expenses for registration of Patents and Trademark was deemed erroneous as it did not follow the prescribed method for determining the Arm's Length Price (ALP). The inclusion of Rs. 1,81,61,306/- as 'Fees for Technical Services' was set aside for fresh consideration by the Assessing Officer. The appeal was allowed partly for statistical purposes, with certain grounds becoming infructuous. Case-Laws Income Tax Wed, 31 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443115