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2016 (7) TMI 678 - DELHI HIGH COURT

2016 (7) TMI 678 - DELHI HIGH COURT - [2016] 386 ITR 1 - Addition 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 .....

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6-07 and 2007-08. - Decided against revenue - ITA 334/2016 - Dated:- 12-7-2016 - S. Muralidhar And Najmi Waziri, JJ. For the Appellant : Mr. Dileep Shivpuri, Sr. Standing Counsel with Mr. Sanjay Kumar, Advocate For the Respondent : Mr. M.S. Syali, Sr. Advocate with Mr. Mayank Nagi and Ms Husnal Syali, Advocates ORDER 1. This appeal by the Revenue is directed against the order dated 14th October 2015 passed by the Income Tax Appellate Tribunal ( ITAT ) in ITA No. 1432/Del/2011 for the Assessment .....

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pursuant to the reference made by the AO, the TPO passed an order dated 13th December, 2006 for the AY in question on the basis of the Transfer Pricing ( TP ) Study submitted by the Assessee. Inter alia, in the order the TPO noted the submission made by the Assessee by its letter dated 8th November 2006 giving the reason for enhancement of the royalty rate from 30% to 56%. The Assessee drew a distinction between the royalty rate that was paid in the earlier years and the 'effective royalty&# .....

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under: 32. We have considered rival submissions and have perused the record of the case. There is no dispute that for distribution division, in the current assessment year, the assessee had adopted TNMM as the arm s length standard for the inter company royalty expenses. The Assessee had earned an OP/sales ratio of 23.3%, which was much more than the mean OP/sales ratio of 2.2% earned by comparable companies. The assessee in June 2003 had changed its royalty arrangement for Oracle Corporation t .....

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