https://www.taxtmi.com/caselaws?id=310738 The ITAT Delhi allowed the assessee's appeal regarding transfer pricing adjustments. The DRP had reduced royalty rate from 8% to 3% based on comparables, but the ITAT found this arbitrary selection lacked proper comparable companies on record. The court determined TNMM as the most appropriate method given the specific facts involving export sales to associated enterprises totaling Rs.24 Cr. against total turnover of Rs.92 Cr. The DRP correctly found TPO's determination of arm's length price at nil for fees for technical services was incorrect due to improper application of CUP method. en-us Mon, 03 Jul 2023 00:00:00 +0530 Thu, 09 Nov 2023 20:50:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310738 The ITAT Delhi allowed the assessee's appeal regarding transfer pricing adjustments. The DRP had reduced royalty rate from 8% to 3% based on comparables, but the ITAT found this arbitrary selection lacked proper comparable companies on record. The court determined TNMM as the most appropriate method given the specific facts involving export sales to associated enterprises totaling Rs.24 Cr. against total turnover of Rs.92 Cr. The DRP correctly found TPO's determination of arm's length price at nil for fees for technical services was incorrect due to improper application of CUP method. Case-Laws Income Tax Mon, 03 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310738