https://www.taxtmi.com/caselaws?id=463403 ITAT allowed the appeal in part. It held that prices charged to non-AEs in India cannot serve as CUPs for arm's-length pricing of finished goods sold to overseas AEs due to geographic market differences, endorsing TNMM benchmarking. The Tribunal reaffirmed earlier findings that CUP was not the appropriate method for benchmarking royalty payments under the same technical-knowhow agreement and disallowed the TPO's CUP-based adjustment. The Tribunal also deleted the transfer-pricing adjustment for interest on ECB, allowing the relevant ground. en-us Fri, 10 Mar 2023 00:00:00 +0530 Sat, 30 Aug 2025 17:27:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463403 ITAT allowed the appeal in part. It held that prices charged to non-AEs in India cannot serve as CUPs for arm's-length pricing of finished goods sold to overseas AEs due to geographic market differences, endorsing TNMM benchmarking. The Tribunal reaffirmed earlier findings that CUP was not the appropriate method for benchmarking royalty payments under the same technical-knowhow agreement and disallowed the TPO's CUP-based adjustment. The Tribunal also deleted the transfer-pricing adjustment for interest on ECB, allowing the relevant ground. Case-Laws Income Tax Fri, 10 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463403