https://www.taxtmi.com/highlights?id=80147 Transfer pricing issues: Royalty arrangement including trademark, know-how upheld based on CUP method over TNMM. Advertisement expenses remanded for fresh determination. Reimbursement of third-party advertisement expenses deleted as commercial expediency beyond TPO's jurisdiction. IT cost allocation and consultancy services/HR cost reimbursements deleted following past orders. Comparables for marketing support services: APITCO, HCCA Business Services, Quippo Valuers, TSR Darashaw excluded; ITDC (ARMS segment), Overseas Manpower, ICRA Management Consulting included based on functional comparability and consistency. TPO directed to recompute ALP for marketing support services accordingly. en-us Tue, 06 Aug 2024 07:50:19 +0530 Tue, 06 Aug 2024 07:50:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=80147 Transfer pricing issues: Royalty arrangement including trademark, know-how upheld based on CUP method over TNMM. Advertisement expenses remanded for fresh determination. Reimbursement of third-party advertisement expenses deleted as commercial expediency beyond TPO's jurisdiction. IT cost allocation and consultancy services/HR cost reimbursements deleted following past orders. Comparables for marketing support services: APITCO, HCCA Business Services, Quippo Valuers, TSR Darashaw excluded; ITDC (ARMS segment), Overseas Manpower, ICRA Management Consulting included based on functional comparability and consistency. TPO directed to recompute ALP for marketing support services accordingly. Highlights Income Tax Tue, 06 Aug 2024 07:50:19 +0530 https://www.taxtmi.com/highlights?id=80147