Tribunal held that following the rule of consistency TPO was directed to adopt TNM method. Tribunal also held that since assessee was beneficiary of AMP expenses or promotion of brand, said transfer pricing adjustment was to be deleted. Following the earlier order adjustment of royalty was directed to be deleted. (AY. 2012-13)
Himalaya Drug Company v. ACIT (2021) 188 ITD 547 (Bang.) (Trib.)
S. 92C : Transfer pricing-Arm’s length price-TNM method-Cost plus method-TNM was directed to be applied-Beneficiary of AMP expenses or promotion of brand, said transfer pricing adjustment was to be deleted-Adjustment of royalty-Directed to be deleted.