TP Adjustment - payment of technical knowhow fees - benchmarking ...

Annual Transfer Pricing Must Reflect Current Year Conditions; Past Findings Are Persuasive, Not Decisive.

October 19, 2023

Case Laws Income Tax AT

TP Adjustment - payment of technical knowhow fees - benchmarking of the transaction - Intragroup services or for that matter any international transaction is required to be benchmarked each year based on the facts and circumstances prevailing in that year considering the economic conditions. Therefore, the findings of the previous year will have only persuasive value, if any, while deciding the transfer pricing adjustment for any year. - AT

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TP Adjustment - payment of technical knowhow fees - benchmarking ...

Annual Transfer Pricing Must Reflect Current Year Conditions; Past Findings Are Persuasive, Not Decisive.

October 19, 2023

Case Laws Income Tax AT

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