https://www.taxtmi.com/caselaws?id=771366 ITAT Ahmedabad upheld CIT(Appeals) order on transfer pricing adjustments. Court confirmed CUP method was inappropriately applied by TPO without eliminating transaction differences. CIT(Appeals) correctly applied Royalty Savings Method under Income Approach for intangible assets valuation, reducing royalty rates to 3.5% for technical know-how and 3% for trademarks based on OECD guidelines. Downward adjustment addition to assessee's income was deleted as unjustified double taxation. For finished goods sales, upward adjustment was scaled down to apply only to Avecia products due to insufficient FAR analysis, reducing adjustment from Rs. 32.84 crores to Rs. 17.77 crores. en-us Mon, 21 Apr 2025 00:00:00 +0530 Sat, 24 May 2025 09:00:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771366 ITAT Ahmedabad upheld CIT(Appeals) order on transfer pricing adjustments. Court confirmed CUP method was inappropriately applied by TPO without eliminating transaction differences. CIT(Appeals) correctly applied Royalty Savings Method under Income Approach for intangible assets valuation, reducing royalty rates to 3.5% for technical know-how and 3% for trademarks based on OECD guidelines. Downward adjustment addition to assessee's income was deleted as unjustified double taxation. For finished goods sales, upward adjustment was scaled down to apply only to Avecia products due to insufficient FAR analysis, reducing adjustment from Rs. 32.84 crores to Rs. 17.77 crores. Case-Laws Income Tax Mon, 21 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771366