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2016 (7) TMI 678 - HC - Income TaxAddition on account of international transactions of payment of royalty - ITAT not confirming the action of the AO in restricting the payment of royalty to 30% of the actual sales as against 56% claimed by the assessee confirmed - Held that:- It has been rightly noted by the ITAT, once the liberalized policy did away with the requirement of computing the royalty with reference to the list price (Indian Published Price), the Assessee moved from the regime of royalty payment as a percentage of the list price to the actual license and support review. In the circumstances, the conclusion arrived at by the ITAT appears to be perfectly justified. It is based on facts and does not give rise to any substantial question of law. It may also be noticed that in the AYs 2008-09 and 2009-10, the TPO has accepted the royalty payment at 56% of the actual sales. Also, the Dispute Resolution Panel has accepted the Assessee’s case for AYs 2006-07 and 2007-08. - Decided against revenue
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