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TPO's approach unsustainable if he rejected assessee's benchmarking of royalty payment without any basis

September 5, 2019[2019] 108 taxmann.com 223 (Mumbai - Trib.)
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TRANSFER PRICING: AMP expenditure incurred by assessee for marketing and promotion of its manufactured ready-to-eat cereal products in India by making payment to third parties in India would not come within purview of international transaction

TRANSFER PRICING: Where assessee benchmarked payment of royalty to its AE by applying CUP method and TPO rejected said benchmarking without any basis/reasoning on which he found it unacceptable and determined ALP of said royalty payment at Nil, his approach was not in accordance with statutory provisions, hence, unsustainable

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