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2016 (12) TMI 936 - AT - Income TaxTPA - determining the arm’s length price of the international transactions - payment of royalty - Held that:- Payment of royalty by the assessee to its associated enterprise, Dow Netherlands @ 5% on domestic sales and 8% on export sales is liable to be considered as at an arm’s length rate in view of the Circular No.5 dated 21/7/2003. Therefore, the addition made by the Assessing Officer on this count is unsustainable. In the ultimate analysis, we uphold the action of the CIT(A) in deleting the addition, albeit, on a different ground.
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