https://www.taxtmi.com/caselaws?id=762793 ITAT Bangalore dismissed revenue's appeal challenging CIT(A)'s order allowing assessee's appeal against TPO's separate benchmarking of royalty payments. The Tribunal held that royalty cannot be separately benchmarked when TPO has already accepted the overall margin as arms length price. CIT(A) correctly ruled that once margins are accepted at arms length, additional separate benchmarking of royalty component is not justified under transfer pricing provisions. en-us Wed, 23 Oct 2024 00:00:00 +0530 Sat, 07 Dec 2024 08:14:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762793 ITAT Bangalore dismissed revenue's appeal challenging CIT(A)'s order allowing assessee's appeal against TPO's separate benchmarking of royalty payments. The Tribunal held that royalty cannot be separately benchmarked when TPO has already accepted the overall margin as arms length price. CIT(A) correctly ruled that once margins are accepted at arms length, additional separate benchmarking of royalty component is not justified under transfer pricing provisions. Case-Laws Income Tax Wed, 23 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762793