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TMI Blog2020 (2) TMI 728X X X X Extracts X X X X X X X X Extracts X X X X ..... rocess and for such use of technology, it has paid the royalty. It then referred to decisions of M/S. TOYOTA KIRLOSKAR AUTO PARTS PVT. LTD. VERSUS ASST. COMMISSIONER OF INCOME-TAX, LTU, BANGALORE. [ 2015 (1) TMI 921 - ITAT BANGALORE] . In a similar case, the Tribunal had remitted the issue to the file of the A.O. to determinate the arm s length price of royalty by adopting TNMM after giving fair ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Hyderabad Bench-A, Hyderabad in relation to the respondent-assessee for the year 2013-14. 2. The respondent-company is engaged in the business of manufacturing high performance flexible disc coupling for application in critical turbo machinery. 3. It filed its return of income for the assessment year 2013-14 on 21-09-2013 declaring an income of ₹ 54,15,52,720/- and showed book profit o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ce therewith, the final assessment order was passed. 7. The assessee then filed the appeal before the Tribunal. 8. It was contended before the Tribunal by the assessee that the issue of determination of the royalty payment at Rs.nil by using the benefit test was considered by the Coordinate Bench of the Tribunal in the case of M/s.Toyota Kirloskar Auto Parts Pvt Ltd. v. ACIT 2015 (1) TMI 9 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ate the arm s length price of royalty by adopting TNMM after giving fair opportunity for hearing. Thus, the Tribunal has only remitted the matter back to the file of AO/TPO and did not adjudicate anything in the appeal and it allowed the appeal only for statistical purpose. 10. In these circumstances, we are not inclined to admit this appeal since after the remand order passed by the Tribunal, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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