https://www.taxtmi.com/caselaws?id=312220 The ITAT Bangalore ruled on transfer pricing adjustments for Global Sale and Marketing Activity Fees. The TPO had accepted all international transactions except these fees. The tribunal held that when multiple international transactions involve both receipts from and payments to associated enterprises, they should be clubbed together and analyzed under TNMM rather than tested separately. The court directed that management fees and Global Sale and Marketing Activity Fees be treated as operating costs and allocated proportionally based on turnover of other international transactions. The matter was remanded to TPO/AO for fresh determination of arm's length price. Additionally, the AO was directed to follow DRP directions regarding foreign tax credit and TDS credit. en-us Fri, 09 Jun 2017 00:00:00 +0530 Wed, 07 Feb 2024 17:58:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312220 The ITAT Bangalore ruled on transfer pricing adjustments for Global Sale and Marketing Activity Fees. The TPO had accepted all international transactions except these fees. The tribunal held that when multiple international transactions involve both receipts from and payments to associated enterprises, they should be clubbed together and analyzed under TNMM rather than tested separately. The court directed that management fees and Global Sale and Marketing Activity Fees be treated as operating costs and allocated proportionally based on turnover of other international transactions. The matter was remanded to TPO/AO for fresh determination of arm's length price. Additionally, the AO was directed to follow DRP directions regarding foreign tax credit and TDS credit. Case-Laws Income Tax Fri, 09 Jun 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312220