ITAT Orders Fresh Benchmarking of Royalty Payments, Prefers Traditional Methods Over TPM

Marks and Spencer (India) Private Limited Vs ACIT (ITAT Delhi) ITAT: Orders fresh benchmarking of royalty payments, prioritizing traditional methods over the transactional profit method Facts: The assessee “Marks and Spencer (India) Private Limited” was incorporated on 01.04.2005 and is a wholly owned subsidiary of Marks and Spencer Investments Pte. Ltd., Singapore (“M&S Singapore”). The assessee is engaged in the wholesale business of procuring and selling branded apparel and accessories, including leather products and toiletries. In addition to its trading activities, the assess...