https://www.taxtmi.com/caselaws?id=444077 The dominant issue was the legality of TP adjustments to international transactions with associated enterprises. For imports of raw materials/components, and for aggregation of fixed-asset purchases and trademark fee with such imports, the Tribunal held that in the absence of any distinguishing facts or contrary binding authority and following its earlier order in the same assessee's case, the DRP's enhancement was unsustainable; the AO/TPO was directed to delete the TP additions, and the assessee's grounds were allowed. For data management and related service fees, the Tribunal similarly rejected the determination of ALP at nil under CUP, following its prior decision; the TP adjustment was deleted and the ground allowed. For reimbursements from AEs, the Tribunal upheld recharacterisation as support services with 5% markup, finding no basis to disturb the DRP's view; the ground was dismissed. en-us Tue, 03 Oct 2023 00:00:00 +0530 Mon, 05 Jan 2026 11:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444077 The dominant issue was the legality of TP adjustments to international transactions with associated enterprises. For imports of raw materials/components, and for aggregation of fixed-asset purchases and trademark fee with such imports, the Tribunal held that in the absence of any distinguishing facts or contrary binding authority and following its earlier order in the same assessee's case, the DRP's enhancement was unsustainable; the AO/TPO was directed to delete the TP additions, and the assessee's grounds were allowed. For data management and related service fees, the Tribunal similarly rejected the determination of ALP at nil under CUP, following its prior decision; the TP adjustment was deleted and the ground allowed. For reimbursements from AEs, the Tribunal upheld recharacterisation as support services with 5% markup, finding no basis to disturb the DRP's view; the ground was dismissed. Case-Laws Income Tax Tue, 03 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444077