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2018 (11) TMI 1697 - HC - Income TaxTP Adjustment - Royalty and Sales Commission paid were separate and independent international transactions which were required to be benchmarked separately by applying the Comparable Uncontrolled Price Method - HELD THAT:- While examining the aforesaid question, the respondent-assessee would be entitled to raise the issue and question that the Assessing Officer had disallowed the entire expenditure on royalty etc. without referring to any comparables by applying “benefit” test. Accordingly, the Tribunal should not have remanded the matter to the Assessing Officer. Filing of printed paper book is dispensed with. However, parties are at liberty to file documents/papers which were part of the assessment or appellate proceedings. Papers/documents would be filed within eight weeks. Admit substantial question of law.
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