Appellate Tribunal decides on Transfer Pricing issues incl. software services, guarantees, inter-company loans, & brand royalties.

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....The Appellate Tribunal addressed various Transfer Pricing (TP) issues. Regarding software services, the Tribunal upheld the selection of comparables by the assessee over the Transfer Pricing Officer's choices. The Tribunal also adjusted rates for guarantees provided to AEs based on performance and financial aspects. For inter-company loans, the Tribunal questioned the characterization as loans without considering the quasi-equity nature argued by the assessee. The Tribunal dismissed a claim for brand royalty fees, affirming that the brand is not owned by the assessee, hence no royalty is applicable.....