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

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