Domestic Royalty Split Not Permissible: Entire TP Adjustment Deleted

Cummins India Limited Vs ACIT (ITAT Pune) 10AA Relief Upheld, 35(2AB) Restored, 14A Partly Sustains- Export–Domestic Royalty Split Not Permissible: Entire TP Adjustment Deleted Pune Tribunal dealt with cross-appeals against TP adjustments & corporate tax issues. AO/TPO had made an upward adjustment of Rs.12.70 Cr by rejecting Aggregation approach & applying CUP only to royalty on export sales, splitting royalty into domestic vs export segments. Tribunal noted that Jurisdictional Bombay High Court, vide judgment dated 28.07.2023 in Assessee’s own cases for AYs 2015-16 to 2017-18, ha...