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2022 (2) TMI 589 - ITAT CHENNAIAddition made on account of unaccounted royalty - HELD THAT:- According to the reconciliation statement filed by the assessee, if methodology considered by the AO is adopted for computing royalty, then royalty income receivable by the assessee from M/s. Ford India Private Limited, shall work out to ₹ 91.68 crores, which is lesser than the amount of royalty income received by the assessee. The facts with regard to consideration of cost associated with those passenger vehicle models which has negative revenue base by the AO is not forthcoming from records. Reconciliation statement filed by the assessee explaining difference between royalty income computed by the assessee and royalty income determined by the AO was also not available with the AO. Therefore, to consider the above aspect and also reconciliation statement filed by the assessee, the issue needs to go back to the file of the AO for fresh consideration. Hence, we set aside the issue to file of the AO and direct the Assessing Officer to reconsider the issue in light of royalty agreement between the parties, revenue base of passenger vehicles assembled in India and reconciliation statement filed by the assessee explaining difference between royalty income computed by the assessee and royalty income determined by the Assessing Officer. Appeal filed by the Revenue is treated as allowed for statistical purposes.
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