https://www.taxtmi.com/caselaws?id=765952 HC upheld ITAT's deletion of TP additions relating to reimbursement of expatriate salaries and royalty payments, rejecting Revenue's claim of double deduction. The Assessee's reimbursement of expatriate costs without mark-up was accepted as ALP, noting absence of required documentation did not negate the commercial expediency of hiring expatriates. The commission income was benchmarked using TNMM and found at arm's length, subsuming expatriate costs. Royalty payments for technical know-how were held to have valid commercial basis and could not be reduced to nil due to business losses. The court found no error in CIT(A) or ITAT decisions setting aside ALP adjustments. Revenue failed to demonstrate double deduction or flaws in the ALP determination, resulting in dismissal of Revenue's appeal. en-us Thu, 06 Feb 2025 00:00:00 +0530 Mon, 04 Aug 2025 16:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765952 HC upheld ITAT's deletion of TP additions relating to reimbursement of expatriate salaries and royalty payments, rejecting Revenue's claim of double deduction. The Assessee's reimbursement of expatriate costs without mark-up was accepted as ALP, noting absence of required documentation did not negate the commercial expediency of hiring expatriates. The commission income was benchmarked using TNMM and found at arm's length, subsuming expatriate costs. Royalty payments for technical know-how were held to have valid commercial basis and could not be reduced to nil due to business losses. The court found no error in CIT(A) or ITAT decisions setting aside ALP adjustments. Revenue failed to demonstrate double deduction or flaws in the ALP determination, resulting in dismissal of Revenue's appeal. Case-Laws Income Tax Thu, 06 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765952