https://www.taxtmi.com/caselaws?id=755662 Transfer pricing adjustment on royalty receipts cannot rest solely on mismatches between amounts reported in Form 3CEB and by associated enterprises. Year-wise differences substantially arose from revenue-recognition timing, differing accounting periods and receipt-based royalty taxability, with substantial reconciliation available. An adjustment made without determining arm's length price through prescribed transfer pricing methods or examining functions, assets and risks was unsustainable. The royalty-related transfer pricing addition was deleted. en-us Wed, 26 Jun 2024 00:00:00 +0530 Tue, 16 Jul 2024 11:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755662 Transfer pricing adjustment on royalty receipts cannot rest solely on mismatches between amounts reported in Form 3CEB and by associated enterprises. Year-wise differences substantially arose from revenue-recognition timing, differing accounting periods and receipt-based royalty taxability, with substantial reconciliation available. An adjustment made without determining arm's length price through prescribed transfer pricing methods or examining functions, assets and risks was unsustainable. The royalty-related transfer pricing addition was deleted. Case-Laws Income Tax Wed, 26 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755662