https://www.taxtmi.com/caselaws?id=755662 ITAT Mumbai allowed the assessee's appeal against transfer pricing adjustments on royalty receipts. The TPO made additions based on differences in amounts reported in Form 3CEB between the assessee and its associated enterprises, without following prescribed methods under Section 92C. The tribunal held that timing differences in revenue recognition between US GAAP and Indian accounting standards do not warrant TP adjustments. The TPO's ad-hoc approach of determining arm's length price without analyzing functions, assets, and risks or following statutory methods was contrary to law and unsustainable. 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 ITAT Mumbai allowed the assessee's appeal against transfer pricing adjustments on royalty receipts. The TPO made additions based on differences in amounts reported in Form 3CEB between the assessee and its associated enterprises, without following prescribed methods under Section 92C. The tribunal held that timing differences in revenue recognition between US GAAP and Indian accounting standards do not warrant TP adjustments. The TPO's ad-hoc approach of determining arm's length price without analyzing functions, assets, and risks or following statutory methods was contrary to law and unsustainable. Case-Laws Income Tax Wed, 26 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755662