Disallowance of payments made for royalty and technical know-how received - Accepted Most appropriate...

The case involves the disallowance of payments made for royalty and technical know-how. The most appropriate method for benchmarking the manufacturing segment was identified as the Transactional Net Margin Method (TNNM). However, the Transfer Pricing Officer (TPO) attempted to apply a different method, the Comparable Uncontrolled Price (CUP) method, solely to the payment of the technical assistance fee. It was determined that the TPO could not isolate this element and apply a different method, emphasizing the need for consistency in the approach used for such assessments. .....

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