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TMI Blog2019 (5) TMI 1331X X X X Extracts X X X X X X X X Extracts X X X X ..... rom the office of the Deputy Commissioner of Income Tax Section 13(2) in regard to the settlement reached between the Assessee and the department under the Mutual Agreement Procedure ( MAP ) between the Competent Authority (CA) of India and CA of UK under Article 27 of the India UK Double Taxation Avoidance Agreement ( DTAA ). This specifically deals with the issue of royalty failed by the Asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... since it no longer survives. - ITA 525/2017 And W.P.(C) 6058/2017 - - - Dated:- 17-5-2019 - S. MURALIDHAR AND I.S. MEHTA JJ. Appellant Through: Mr. M.S. Syali, Sr. Advocate with Mr. Mayank Nagi, Mr. Tarun Singh Mr. Hardeep Singh Chawla, Advocates. Respondent Through: Mr. Ruchir Bhatia, Sr. Standing Counsel. O R D E R 1. The present appeal is aga ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nly grievance raised in this appeal is against the addition of ₹ 156,38,82,889/- made by the AO on account of transfer pricing adjustment. 3. Inasmuch as the ITAT has remanded the matter to the Transfer Pricing Officer ( TPO ) for a fresh determination of the arm s length price (ALP) of the transaction of payment of royalty by applying the decision of this Court in CIT v. Cushma ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Commissioner of Income Tax Section 13(2) in regard to the settlement reached between the Assessee and the department under the Mutual Agreement Procedure ( MAP ) between the Competent Authority (CA) of India and CA of UK under Article 27 of the India UK Double Taxation Avoidance Agreement ( DTAA ). This specifically deals with the issue of royalty failed by the Assessee during the AY in questio ..... X X X X Extracts X X X X X X X X Extracts X X X X
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