Saturday 22 March 2014

Royalty paid by assessee to AE not comparable with royalty paid by AE further as method of computati

IT/ILT : Where TPO having found that royalty paid by assessee to its AE was higher as compared to similar payment made by another AE, added certain amount to assessee's ALP, in view of fact that assessee had paid royalty on net sales of product whereas other AE made payment on gross sales receipts, there being difference in mode of computation of royalty, impugned addition was to be set aside


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