https://www.taxtmi.com/caselaws?id=771370 ITAT Hyderabad allowed the assessee's appeal for statistical purposes in a transfer pricing case involving management and technical assistance services payments to an associated enterprise. The TPO had made adjustments despite accepting other international transactions at arm's length. The tribunal noted that since TDS was deducted and the AE offered income to tax in India, there was no profit shifting. The court remanded the matter to TPO for proper examination of additional evidence, agreements, and technical know-how formulas, emphasizing that formula provision differs from continuous raw material transactions and requires thorough verification before determining arm's length price. en-us Tue, 06 May 2025 00:00:00 +0530 Sat, 24 May 2025 09:00:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771370 ITAT Hyderabad allowed the assessee's appeal for statistical purposes in a transfer pricing case involving management and technical assistance services payments to an associated enterprise. The TPO had made adjustments despite accepting other international transactions at arm's length. The tribunal noted that since TDS was deducted and the AE offered income to tax in India, there was no profit shifting. The court remanded the matter to TPO for proper examination of additional evidence, agreements, and technical know-how formulas, emphasizing that formula provision differs from continuous raw material transactions and requires thorough verification before determining arm's length price. Case-Laws Income Tax Tue, 06 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771370