Transfer Pricing Dispute: Reassessing Methods for Arm's Length Pricing in Services and Royalties, Remand for Fresh Evaluation.

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....Transfer pricing adjustments, selection of the most appropriate method (MAM), benchmarking approach (aggregation or segregation), factual rendering of services, arm's length pricing (ALP) determination for various transactions like Technical Support Services (TSS), Business Support Services (BSS), and royalty payments. It highlights the inconsistencies in the approach adopted by the Transfer Pricing Officer (TPO) and the Dispute Resolution Panel (DRP) compared to previous years, lack of proper consideration of evidence and contentions raised by the assessee, and the need for remitting the matter back to the TPO for a fresh determination considering all relevant factors, including landed cost of imported components for comparables in the case of royalty transactions.....