Pune ITAT Deletes ₹5.67 Crore TP Adjustment; TPO Cannot Cherry-Pick One Transaction While Accepting TNMM for Others

L&L Product India Private Limited Vs Assessment Unit (ITAT Pune) Pune ITAT Deletes ₹5.67 Crore TP Adjustment; TPO Cannot Cherry-Pick One Transaction While Accepting TNMM for Others On the issue of royalty payment, the Tribunal observed that the assessee had incurred R&D expenses of ₹2.52 crore and had already recovered ₹2.77 crore from its Associated Enterprises with a markup of about 10%. Since the assessee had already been compensated for the R&D services rendered, the additional TP adjustment of ₹23.26 lakh made by the TPO was found to be unjustified and was deleted. Reg...