Tribunal Upholds TNMM for Transfer Pricing; Adjusts Brokerage Commissions, Royalty Payments, and Reimbursements.

The Appellate Tribunal considered TP adjustment on brokerage commission received from related parties. It found TNMM method appropriate for benchmarking the commission rates. Also, it held that higher commission rates for non-related parties should be arm's length for related parties. The Tribunal allowed the appeal, holding TNMM as the preferred method. Regarding royalty payments, the Tribunal upheld TNMM method for benchmarking, rejecting internal CUP and external CUP due to lack of comparable data. Indirect cost reimbursement was scrutinized, with the Tribunal directing deletion of the addition made by AO/TPO. Additionally, the Tribunal ruled in favor of the assessee for outstanding securities tax and TDS issues, directing deletions of disallowances. The Tribunal allowed the appeal on various grounds, maintaining consistency with prior rulings. .....

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