https://www.taxtmi.com/caselaws?id=756573 The ITAT Delhi ruled on multiple transfer pricing issues involving royalty payments and service transactions. For royalty arrangements covering trademark and technical know-how, the Tribunal rejected the TPO's TNMM method and upheld the assessee's CUP method, following coordinate bench precedents. The addition on royalty was deleted in favor of the assessee. Advertisement expenses were remanded to TPO for fresh determination. Reimbursement of advertisement expenses by Associated Enterprise was allowed, with the Tribunal holding TPO lacked jurisdiction to question commercial expediency. IT cost allocation and consultancy services adjustments were deleted following consistent tribunal precedents. For market support services, several comparables were excluded based on functional differences, while specific companies were retained or included based on comparability analysis. en-us Wed, 24 Jul 2024 00:00:00 +0530 Mon, 05 Aug 2024 12:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756573 The ITAT Delhi ruled on multiple transfer pricing issues involving royalty payments and service transactions. For royalty arrangements covering trademark and technical know-how, the Tribunal rejected the TPO's TNMM method and upheld the assessee's CUP method, following coordinate bench precedents. The addition on royalty was deleted in favor of the assessee. Advertisement expenses were remanded to TPO for fresh determination. Reimbursement of advertisement expenses by Associated Enterprise was allowed, with the Tribunal holding TPO lacked jurisdiction to question commercial expediency. IT cost allocation and consultancy services adjustments were deleted following consistent tribunal precedents. For market support services, several comparables were excluded based on functional differences, while specific companies were retained or included based on comparability analysis. Case-Laws Income Tax Wed, 24 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756573