Monday, 22 September 2014

Technical payments to AEs couldn’t be held as nil if payments under technical agreement were duly ap

IT/ILT: Where TPO made adjustment to assessee's ALP taking a view that value of technical know how fee and royalty paid by assessee to its promoter company was nil, in view of fact that technical service agreement was duly approved by RBI and, moreover, TPO had not analysed payments in question either under TNMM method or under any other method as required by transfer pricing provisions, impugned disallowance made by TPO was to be set aside


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