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2021 (10) TMI 669 - AT - Income TaxTP Adjustment - TPO considered royalty payment as a separate international transaction and proceeded to test the royalty transaction separately by applying comparable uncontrolled transaction - HELD THAT:- Rejection of the two comparables by the TPO, are based on conjectures and surmises. It is pertinent to note that the filters used by the TPO does not indicate that the high rates in respect of determination of ALP of royalty is one of the criteria of the rejection while confronting the assessee. The ratio laid down by the Hon'ble High Court in case of ChrysCapital Investment [2015 (4) TMI 949 - DELHI HIGH COURT] is applicable in the present case. Hence there is no need to interfere with the findings of the CIT(A). The appeal of the Revenue is dismissed.
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