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2018 (2) TMI 1088 - AT - Income TaxAdjustment on account of royalty payment - ALP adjustment - Held that:- Since the issue as to payment of royalty by the taxpayer to its AE is one of the actual business arrangement, there is no material on file to take a different view on the issue as the same has already been settled in favour of the taxpayer in AY 2010-11 and AY 2011-12, so ALP adjustment on account of royalty payment made by the TPO/AO is not sustainable in the eyes of law, hence ordered to be deleted by the AO. Consequently, the appeal filed by the taxpayer is hereby allowed.
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