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2020 (2) TMI 1704 - ITAT MUMBAIDetermination of payment of trademark royalty of Cadbury Schweppes Overseas Limited [CSOL] - TP adjustment on account of payment of trademark royalty to CSOL - HELD THAT:- It is clear from the above decision of the Tribunal [2018 (11) TMI 1762 - ITAT MUMBAI] that the royalty payment of trademark used held within arm’s length and does not call for any adjustment. There being no difference in the factual position in the impugned assessment year, therefore, respectfully following the order of the Tribunal on identical facts in assessee’s own case we hold that royalty payment on trademark to CSOL, 1% of net sale is at arm’s length, hence, no further adjustment is required. The ld DR has fairly conceded that the issue is covered by the decision of the Tribunal in assessee’s own case. Appeal of the assessee is allowed.
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