Tuesday 26 May 2015

Sum paid to AE for use of its trademark couldn't be disallowed even if assessee's own trademark was

IT/ILT : Where TPO disallowed payment of royalty made by assessee to its AE on sales, in view of fact that there were no comparable companies offering similar services comparison made by TPO on basis of transactions of assessee's subsidiary company much prior to year under consideration could not be considered as internal CUP and, consequently, impugned disallowance was to be deleted

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