Obviously, when the assessee is using patents/trademarks of its ...

Income Tax

March 11, 2016

Obviously, when the assessee is using patents/trademarks of its parent company, it will have to pay royalty for the same which cannot be disallowed, unless it is not at arm’s length price. - AT

View Source

← Previous Next →

Obviously, when the assessee is using patents/trademarks of its ...

Income Tax

March 11, 2016

You may also like:

Royalty Benchmarking - assessee had adopted TNMM at the entity level in which process royalty payment is considered as closely linked transaction and part of operating...

Royalty paid treated as capital expenses - the assessee company did not obtain any proprietary or ownership right of trademark or knowhow, no asset was created or...

TP Adjustment - international transaction involving payment of royalty undertaken by Diesel India with its Associated Enterprise (“AE”) - the arithmetic mean of...

Income taxable in India - PE in India - Once we hold that in the light of the present legal position, existence of dependent agency permanent establishment in wholly tax...

Payment for use of technical know-how and trademark/logo - it is patent that the payment has been made by the assessee for ‘use of ’ trademarks and not for acquiring...

TP Adjustment - Determination of arm’s-length price - Law does not permit the TPO or DRP to determine the arm’s length price on estimation or adhoc basis. - Accordingly...

Comparison - Arm’s length price – Comparability of price with the chosen company - assessee's contention that assessee is in merely functional advisory consultancy...

TPA - the jurisdiction and power of TPO is to determine arm's length price of Royalty and the order of TPO holding that the assessee had not derived any benefit under...

Addition towards adjustment of Arm’s Length Price - The seven sets of international transactions undertaken by the assessee cannot be considered as ‘closely linked’. - AT

Transfer pricing adjustment deleted - the comparables adopted by the assessee are uncontrolled parties and can be considered for the purpose of determining the Arms'...

Quick Updates: