https://www.taxtmi.com/highlights?id=79464 Royalty receipts were subject to transfer pricing adjustment by TPO on basis of differences in amounts reflected in Form 3CEB of assessee vis-à-vis its group entities, without computing ALP by prescribed methods u/s 92C. TPO's approach of determining ALP merely based on differences in reporting by assessee and AEs, without considering functions, assets, risks involved in transactions, is ad-hoc and contrary to transfer pricing provisions. TPO must determine ALP by following prescribed methods; additions cannot be made on ad-hoc basis. Differences arose due to timing of revenue recognition under US GAAP followed by assessee. Major differences were reconciled; remaining differences were minimal, not warranting income addition. TPO's approach was held unsustainable in law. en-us Wed, 17 Jul 2024 08:05:52 +0530 Wed, 17 Jul 2024 08:05:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=79464 Royalty receipts were subject to transfer pricing adjustment by TPO on basis of differences in amounts reflected in Form 3CEB of assessee vis-à-vis its group entities, without computing ALP by prescribed methods u/s 92C. TPO's approach of determining ALP merely based on differences in reporting by assessee and AEs, without considering functions, assets, risks involved in transactions, is ad-hoc and contrary to transfer pricing provisions. TPO must determine ALP by following prescribed methods; additions cannot be made on ad-hoc basis. Differences arose due to timing of revenue recognition under US GAAP followed by assessee. Major differences were reconciled; remaining differences were minimal, not warranting income addition. TPO's approach was held unsustainable in law. Highlights Income Tax Wed, 17 Jul 2024 08:05:52 +0530 https://www.taxtmi.com/highlights?id=79464