https://www.taxtmi.com/caselaws?id=313888 The ITAT Mumbai ruled on transfer pricing adjustments involving software license fees and cost allocations. The TPO had treated the arm's length price as NIL for time and billing software payments to associated enterprises without applying prescribed methods under section 92C. Following precedents from Bombay HC cases including Lever India Exports and Merck Ltd., the tribunal allowed the assessee's grounds regarding software fees and cost allocations. For regional coordination services comparability, the matter was remitted back to TPO for fresh analysis of additional submissions. The tribunal also directed the AO to consider extending interest benefits under section 244A until actual refund receipt, following the Small Industries precedent. en-us Wed, 28 Feb 2024 00:00:00 +0530 Mon, 16 Dec 2024 11:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313888 The ITAT Mumbai ruled on transfer pricing adjustments involving software license fees and cost allocations. The TPO had treated the arm's length price as NIL for time and billing software payments to associated enterprises without applying prescribed methods under section 92C. Following precedents from Bombay HC cases including Lever India Exports and Merck Ltd., the tribunal allowed the assessee's grounds regarding software fees and cost allocations. For regional coordination services comparability, the matter was remitted back to TPO for fresh analysis of additional submissions. The tribunal also directed the AO to consider extending interest benefits under section 244A until actual refund receipt, following the Small Industries precedent. Case-Laws Income Tax Wed, 28 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313888