https://www.taxtmi.com/caselaws?id=447498 ITAT Mumbai held that the "Other Method" under Rule 10AB r.w.s. 92C(1) is the most appropriate method (MAM) for benchmarking royalty payments to associated enterprises, rather than the Comparable Uncontrolled Price (CUP) method. The tribunal found CUP unsuitable due to lack of reliable comparables and unique nature of intangibles involved. The Transfer Pricing Officer was directed to adopt the Other Method as MAM, requiring fresh examination of costs and profits attributable to manufacturing, sales to non-AEs, and royalty allocation. All grounds raised by the assessee were allowed for statistical purposes. en-us Wed, 19 Apr 2023 00:00:00 +0530 Thu, 28 Dec 2023 08:43:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447498 ITAT Mumbai held that the "Other Method" under Rule 10AB r.w.s. 92C(1) is the most appropriate method (MAM) for benchmarking royalty payments to associated enterprises, rather than the Comparable Uncontrolled Price (CUP) method. The tribunal found CUP unsuitable due to lack of reliable comparables and unique nature of intangibles involved. The Transfer Pricing Officer was directed to adopt the Other Method as MAM, requiring fresh examination of costs and profits attributable to manufacturing, sales to non-AEs, and royalty allocation. All grounds raised by the assessee were allowed for statistical purposes. Case-Laws Income Tax Wed, 19 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447498