ITAT Deletes TP Adjustments on Royalty and Management Services

The Pune Bench of the Income Tax Appellate Tribunal, deleted transfer pricing adjustments relating to royalty payments and management support services. 

The Tribunal held that the assessee had already recovered its R&D costs with an appropriate mark-up and that the TPO was not justified in isolating management support services from other closely linked international transactions for separate benchmarking.