https://www.taxtmi.com/caselaws?id=754908 ITAT Mumbai dismissed Revenue's appeal regarding transfer pricing adjustments for software services provider. The Tribunal upheld CIT(A)'s comparable selection for TNMM benchmarking of software and consultancy services to associated enterprises, finding no merit in Revenue's challenge to detailed comparability analysis. For guarantee provisions, rates were modified: performance guarantee at 0.88%, finance guarantee at 0.77%, and lease guarantee at 0.88% with 60% restriction. Inter-company loans issue was remanded for proper examination of quasi-equity nature and shareholder activity claims. Brand royalty adjustment was rejected as assessee was not the trademark owner, confirming no royalty obligation to associated enterprises. en-us Fri, 21 Jun 2024 00:00:00 +0530 Tue, 02 Jul 2024 14:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754908 ITAT Mumbai dismissed Revenue's appeal regarding transfer pricing adjustments for software services provider. The Tribunal upheld CIT(A)'s comparable selection for TNMM benchmarking of software and consultancy services to associated enterprises, finding no merit in Revenue's challenge to detailed comparability analysis. For guarantee provisions, rates were modified: performance guarantee at 0.88%, finance guarantee at 0.77%, and lease guarantee at 0.88% with 60% restriction. Inter-company loans issue was remanded for proper examination of quasi-equity nature and shareholder activity claims. Brand royalty adjustment was rejected as assessee was not the trademark owner, confirming no royalty obligation to associated enterprises. Case-Laws Income Tax Fri, 21 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754908