Toyota Kirloskar Motor P. Ltd. v. Dy. CIT (2025) 129 ITR 515 (Bang.)(Trib.)

S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Royalty-Benchmarking-Transactional Net Margin Method adopted at entity level-Separate benchmarking of royalty not warranted.

The Transfer Pricing Officer proposed a separate benchmarking of royalty paid by the assessee to its associated enterprises on the ground that the Transactional Net Margin Method (TNMM) was not the most appropriate method for benchmarking the royalty transaction. The Tribunal, following its decisions in the assessee’s own case for the earlier assessment years, held that where TNMM had been accepted and applied at the entity level, no separate benchmarking of royalty was called for. Accordingly, the transfer pricing adjustment proposed in respect of royalty was deleted. (AY. 2018-19).

Leave a Reply

Your email address will not be published. Required fields are marked *

*