https://www.taxtmi.com/caselaws?id=753489 The ITAT Ahmedabad upheld CIT(A)'s decision allowing transfer pricing adjustments for royalty, management fees, and IT allocation costs. For royalty payments at 5.05% to Singapore AE, the tribunal found the assessee correctly applied external CUP method and the rate aligned with RBI regulations, reducing it to 5% of net sales. Management fees with 15% markup were deemed appropriate as actual costs were substantiated and similar payments were accepted in previous years. IT services and technical support costs were allowed as reimbursements of actual expenses incurred by the AE, with proper documentation provided. The tribunal dismissed revenue's appeal, finding no factual discrepancies compared to earlier assessment years. en-us Thu, 30 May 2024 00:00:00 +0530 Mon, 03 Jun 2024 09:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753489 The ITAT Ahmedabad upheld CIT(A)'s decision allowing transfer pricing adjustments for royalty, management fees, and IT allocation costs. For royalty payments at 5.05% to Singapore AE, the tribunal found the assessee correctly applied external CUP method and the rate aligned with RBI regulations, reducing it to 5% of net sales. Management fees with 15% markup were deemed appropriate as actual costs were substantiated and similar payments were accepted in previous years. IT services and technical support costs were allowed as reimbursements of actual expenses incurred by the AE, with proper documentation provided. The tribunal dismissed revenue's appeal, finding no factual discrepancies compared to earlier assessment years. Case-Laws Income Tax Thu, 30 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753489