TP Adjustment - Technical know-how fees paid by Appellant to its Associated Enterprise - For the year...

TP Adjustment - Technical know-how fees paid by Appellant to its Associated Enterprise - For the year under consideration (AY 204-15), we notice that TPO has applied Benefit Test which is not as per the rules prescribed under Rule 10B & 10AB of Income Tax Rules. In our view, the payment of Technical knowhow was never bench marked in the earlier AYs. .....

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