https://www.taxtmi.com/caselaws?id=312675 ITAT Bangalore set aside the determination of arm's length price (ALP) for royalty payments to associated enterprises, directing the Transfer Pricing Officer to apply Transactional Net Margin Method (TNMM) as the most appropriate method instead of Profit Split Method, following precedent from earlier assessment years. Regarding dividend distribution tax on non-resident shareholders, the tribunal remanded the matter to TPO/Assessing Officer for fresh consideration due to conflicting ITAT decisions and lack of finality on the issue. The appeal was partly allowed for statistical purposes. en-us Mon, 23 May 2022 00:00:00 +0530 Fri, 01 Mar 2024 18:03:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312675 ITAT Bangalore set aside the determination of arm's length price (ALP) for royalty payments to associated enterprises, directing the Transfer Pricing Officer to apply Transactional Net Margin Method (TNMM) as the most appropriate method instead of Profit Split Method, following precedent from earlier assessment years. Regarding dividend distribution tax on non-resident shareholders, the tribunal remanded the matter to TPO/Assessing Officer for fresh consideration due to conflicting ITAT decisions and lack of finality on the issue. The appeal was partly allowed for statistical purposes. Case-Laws Income Tax Mon, 23 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312675