ITAT Ahmedabad Affirms Arm's Length Price Using CUP Method; Dismisses Revenue's Objections on TP Adjustments.

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....The ITAT Ahmedabad addressed Transfer Pricing (TP) adjustments, focusing on royalty, management fees, and IT allocation costs. The tribunal upheld the use of the Comparable Uncontrolled Price (CUP) method by the assessee, finding it suitable for determining the Arm's Length Price (ALP). The payment of royalty at 5% was deemed comparable with rates allowed by the Indian Regulatory Authority. The tribunal dismissed the Revenue's contentions on royalty payments. Regarding management fees, the tribunal found the markup of 15% justified based on actual costs incurred. The tribunal also upheld the payment for IT services, technical support, and management fees, noting detailed reimbursement provided by the assessee. The CIT(A) decisions were upheld, with no interference warranted. The tribunal dismissed the Revenue's challenges on all three aspects of TP adjustments.....