9911796707
TMI Blog2024 (3) TMI 1379X X X X Extracts X X X X X X X X Extracts X X X X ..... the aspect of royalty may have constituted the subject matter of the AYs as noticed by us hereinabove, the issue of technical know-how fee did not form the subject matter of consideration in AYs 2011-12, 2012-13 and 2013-14. We note that undisputedly in AY 2010-11, both aspects were duly examined by the DRP. The direction as framed by the DRP in terms of the statutory regime which prevails would ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the ITAT is correct in deleting the adjustment pertaining to Royalty and payment of Technical fee, ignoring the fact that for A.Y, 2009-10, the evidences produced by the assessee have already been considered at the level of the TPO? B. Whether on facts and in the circumstances of the case and also prevailing law, the ITAT is justified in ignoring the fact that every year is different and independe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s for technical services paid by the respondent/assessee to its Associated Enterprise (AE), namely, Woodward Governor Company, USA, was tenable in law and on facts? 3. As is evident from the aforesaid extract, the principal question was with respect to the upward adjustments directed and pertaining to royalty and fee for technical services paid by the assessee. It was in the aforesaid context that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... note that undisputedly in AY 2010-11, both aspects were duly examined by the DRP. The direction as framed by the DRP in terms of the statutory regime which prevails would clearly bind the Assessing Officer. 7. In view of the above, and bearing in mind the consistent approach which has been adopted for subsequent years, we find no justification to entertain the instant appeal. Consequently, we see ..... X X X X Extracts X X X X X X X X Extracts X X X X
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