https://www.taxtmi.com/caselaws?id=313876 The ITAT Mumbai held in favor of the assessee regarding transfer pricing adjustments. The TPO had determined the arm's length price (ALP) of royalty and branding fees at nil, claiming no independent enterprise pays brand fees. The Tribunal found that brand promotes business in the broking industry and serves as a profit driver, rejecting the TPO's application of the CUP method due to insufficient information. The assessee's 1% royalty payment was deemed justified as comparable companies incurred 6.4% business development expenditure versus assessee's 1.28%. The Tribunal also deleted adjustments on referral fees and indirect overhead reimbursements, accepting the assessee's TNMM benchmarking approach over the TPO's ad-hoc methodology. en-us Fri, 21 Apr 2023 00:00:00 +0530 Mon, 06 May 2024 20:05:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313876 The ITAT Mumbai held in favor of the assessee regarding transfer pricing adjustments. The TPO had determined the arm's length price (ALP) of royalty and branding fees at nil, claiming no independent enterprise pays brand fees. The Tribunal found that brand promotes business in the broking industry and serves as a profit driver, rejecting the TPO's application of the CUP method due to insufficient information. The assessee's 1% royalty payment was deemed justified as comparable companies incurred 6.4% business development expenditure versus assessee's 1.28%. The Tribunal also deleted adjustments on referral fees and indirect overhead reimbursements, accepting the assessee's TNMM benchmarking approach over the TPO's ad-hoc methodology. Case-Laws Income Tax Fri, 21 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313876