ITAT Rules on Transfer Pricing: Upholds TPO's Unit Treatment, Remands Tested Parties Issue, Adjusts Brand Fees and Comparables.

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....The Income Tax Appellate Tribunal (ITAT) adjudicated on various transfer pricing issues concerning an assessee. Regarding segmentation of business activities, the ITAT upheld the Transfer Pricing Officer's (TPO) approach of treating the UDS and CM segments as a composite unit for determining the arm's length price, dismissing the assessee's claim of separate segments. However, on the issue of rejecting overseas associated enterprises as tested parties, the ITAT remanded the matter to the TPO for re-adjudication after obtaining necessary details and providing due opportunity to the assessee. The ITAT deleted the TPO's upward adjustment for brand development fees, relying on coordinate bench rulings that such expenditures are not internationa.........