https://www.taxtmi.com/caselaws?id=789199 Transfer pricing adjustments on reimbursements and royalty were examined on an arm's length basis. Reimbursement of personnel cost and IT-related expenses was deleted because the assessee showed cost-to-cost recovery without markup and supported the claim with records, while the royalty adjustment was also deleted because internal and external CUP material and technical documentation supported the benchmarking, and the issue was covered by earlier orders in the assessee's own case. By contrast, the adjustment on advertisement and publicity expenses was sustained because the assessee did not produce adequate evidence of business nexus, necessity, or incurrence to establish arm's length treatment. en-us Thu, 02 Apr 2026 00:00:00 +0530 Sat, 04 Apr 2026 08:53:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789199 Transfer pricing adjustments on reimbursements and royalty were examined on an arm's length basis. Reimbursement of personnel cost and IT-related expenses was deleted because the assessee showed cost-to-cost recovery without markup and supported the claim with records, while the royalty adjustment was also deleted because internal and external CUP material and technical documentation supported the benchmarking, and the issue was covered by earlier orders in the assessee's own case. By contrast, the adjustment on advertisement and publicity expenses was sustained because the assessee did not produce adequate evidence of business nexus, necessity, or incurrence to establish arm's length treatment. Case-Laws Income Tax Thu, 02 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789199