https://www.taxtmi.com/caselaws?id=768473 The ITAT Jaipur upheld the TPO's transfer pricing adjustments for international transactions between the assessee and its associate enterprise. The tribunal rejected the assessee's contention that royalty payments should be benchmarked collectively with manufacturing activities, finding them to be separate transactions. The DRP's findings on method selection were deemed adequate, and the TNMM method applied by TPO was validated. The tribunal also rejected the assessee's request to introduce additional evidence regarding royalty agreements, finding no substantial cause for allowing such evidence. The assessment regarding raw material purchases and royalty payments to the associate enterprise was upheld in its entirety. en-us Thu, 23 Jan 2025 00:00:00 +0530 Tue, 08 Apr 2025 08:46:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768473 The ITAT Jaipur upheld the TPO's transfer pricing adjustments for international transactions between the assessee and its associate enterprise. The tribunal rejected the assessee's contention that royalty payments should be benchmarked collectively with manufacturing activities, finding them to be separate transactions. The DRP's findings on method selection were deemed adequate, and the TNMM method applied by TPO was validated. The tribunal also rejected the assessee's request to introduce additional evidence regarding royalty agreements, finding no substantial cause for allowing such evidence. The assessment regarding raw material purchases and royalty payments to the associate enterprise was upheld in its entirety. Case-Laws Income Tax Thu, 23 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768473