https://www.taxtmi.com/caselaws?id=760329 A MAP settlement for transactions with UK entities could not be mechanically extended to royalty paid to non-UK associated enterprises because the transaction context differed. The arm's length price for the non-UK royalty payments had to be determined independently on the facts and in accordance with law, rather than by automatically applying the UK MAP rate. The issue was therefore remitted to the AO/TPO for fresh consideration, with partial relief to the assessee on this ground. en-us Tue, 15 Oct 2024 00:00:00 +0530 Fri, 18 Oct 2024 12:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760329 A MAP settlement for transactions with UK entities could not be mechanically extended to royalty paid to non-UK associated enterprises because the transaction context differed. The arm's length price for the non-UK royalty payments had to be determined independently on the facts and in accordance with law, rather than by automatically applying the UK MAP rate. The issue was therefore remitted to the AO/TPO for fresh consideration, with partial relief to the assessee on this ground. Case-Laws Income Tax Tue, 15 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760329