The Tribunal ruled in favor of the assessee on several transfer ...

Landmark TP ruling - Deleted royalty adjustment, granted working capital adjustment & excluded comparable.

December 17, 2024

Case Laws Income Tax AT

The Tribunal ruled in favor of the assessee on several transfer pricing issues. Firstly, it deleted the TP adjustment on royalty and service fee payments, following its earlier decisions in the assessee's own case. Secondly, it directed granting a working capital adjustment while computing the arm's length price, consistent with its prior ruling for the assessee. Thirdly, it excluded the comparable Axis Integrated Systems Limited from the final set, aligning with an earlier order. The Tribunal also upheld the assessee's revenue recognition policy for sales and marketing support services, relying on judicial precedents. Additionally, it instructed recomputing tax liability without levying interest u/ss 234A and 234C, as the assessee had paid advance tax within statutory timelines.

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The Tribunal ruled in favor of the assessee on several transfer ...

Landmark TP ruling - Deleted royalty adjustment, granted working capital adjustment & excluded comparable.

December 17, 2024

Case Laws Income Tax AT

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