Transfer pricing adjustments, historical royalty, straight-line lease rents, and block depreciation are allowed; warranty provision is remanded.
Transfer pricing adjustments, historical royalty, straight-line lease rents, and block depreciation are allowed; warranty provision is remanded. Issue Whether the revenue authorities are legally justified in: Determinining the Arm’s Length Price (ALP) of intra-group technical services and royalty as “nil” despite documented commercial benefits. Capitalizing recurring royalty expenses that were treated as revenue expenditures in… Read More »