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2017 (3) TMI 1639 - HC - Income TaxBenchmarking of management fee - payment of royalty - MAM - CUP OR TNMM - Held that:- This Court is of the opinion that having regard to the previous decision in EKL Appliances [2012 (4) TMI 346 - DELHI HIGH COURT] as held we are of the opinion that once TNMM has been applied to the assessee company's transaction, it covers within its ambit the royalty transactions in question too and hence the Department's contention for applying the CUP method is erroneous. The ratio of which was correctly applied, no substantial question of law arises. On the first issue, i.e. management fees, the matter stands remitted by the ITAT. The appeal is accordingly dismissed with the pending application.
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