International Tech Company Loses Transfer Pricing Appeal, Tribunal Validates TPO's Methodology for Royalty and Technical Assistance Payments

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....ITAT adjudicated transfer pricing dispute involving international transactions between an assessee and its Associate Enterprise. The tribunal upheld the transfer pricing officer's (TPO) methodology, rejecting the assessee's contentions regarding benchmarking of royalty and technical assistance payments. The key findings include: (1) royalty transactions were determined to be separate class of transactions, not intrinsically linked to manufacturing activities, (2) comparable agreements were scrutinized, and (3) additional evidence was denied admission. The assessment order regarding payments for raw material purchases through international transactions was affirmed, with the tribunal finding no merit in the assessee's arguments challenging the transfer pricing methodology and rejecting proposed alternative methods of computation.....