Transfer Pricing Adjustment: TPO Must Apply APA Parameters for Non-UK Entity Royalty Payments, Same as UK Entities

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....ITAT addressed transfer pricing adjustment concerning royalty payments for licensed manufacturing between appellant and non-UK entities. The tribunal determined that TPO's approach lacked objectivity in differentiating between UK and non-UK AEs, particularly given prior MAP proceedings accepting 4-5% compensation for AY 2013-14 and APA for AY 2018-19 to 2022-23. While MAP/APA decisions lack precedential value for different assessees, they carry significant persuasive weight for the same assessee. Applying consistency principles in tax matters, ITAT directed TPO to accept APA parameters for determining ALP of disputed transactions with non-UK AEs, effectively aligning treatment of royalty payments across jurisdictions.....