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Income Tax - Highlights / Catch Notes

Home Highlights December 2021 Year 2021 This

TP Adjustment - The product licenses were held by the AE who was ...

Case Laws     Income Tax

December 15, 2021

TP Adjustment - The product licenses were held by the AE who was also responsible for maintenance of the product licenses. The manufacturing was done in strict adherence to Product License and the labeling on products was of assessee’s AE. The same is evident from Technical agreement (page no. 342-356 of the Paper Book) between the assessee and FDC-UK (AE). In case of non-AE sales, these expenses are to be borne by the assessee, which fact remains undisputed before us. Therefore, the adjustment of this component has rightly been allowed by Ld. CIT(A). - AT

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