Once the RBI approval of royalty rate was obtained the payment ...

RBI-approved royalty payments deemed fair; TPO's decision to cap payments at 2% of net sales challenged.

October 28, 2014

Case Laws Income Tax AT

Once the RBI approval of royalty rate was obtained the payment was considered to be held at arm's-length - the TPO erred in holding that no tangible benefits were derived by the assessee out of royalty payments made by it and restricted the payment to 2% of net sales - AT

View Source

← Previous Next →

Once the RBI approval of royalty rate was obtained the payment ...

RBI-approved royalty payments deemed fair; TPO's decision to cap payments at 2% of net sales challenged.

October 28, 2014

Case Laws Income Tax AT

You may also like:

Royalty Benchmarking - assessee had adopted TNMM at the entity level in which process royalty payment is considered as closely linked transaction and part of operating...

CESTAT ruled against inclusion of 4% running royalty in transaction value of imported goods under Rule 10(1)(c) of Customs Valuation Rules, 2007. The Tribunal found that...

Challenge to an approved Resolution Plan where no consideration was given to payment to an Operational Creditor. The key points are: Section 30(2)(b) mandates that...

Cash transactions proposed to be capped at ₹ 2 lakh

TPA - ALP of payment of royalty u/s 92CA(3) - TPO instead of applying of the specified scientific methods went on to the justification of the purchase made in the...

Section 12AA(2) of the Income Tax Act, 1961 does not recognize any deemed grant of registration if the application is not decided within six months. The Supreme Court in...

Claim of interest for delayed payment - The RBI has wide supervisory powers over financial institutions like SIDBI, in furtherance of which, any direction issued by the...

Demonetization - Scope of the term "Any" - Validity of N/N. 3407(E) dated 8th November 2016, issued by the Central Government in exercise of the powers conferred by...

Royalty payments under a Licence and Technical Assistance Agreement were not addable to the transaction value of imported goods. The agreement covered transfer of...

Additions u/s 2(22)(e) on account of deemed dividend - Accumulated profit - As per the provision of Explanation 2, all the profits of the company up to the date of...

Transaction is approved by the RBI and Government is not sufficient and the assessee has to benchmark the royalty payment separately - Income Tax

Deemed dividend u/s 2(22)(e) arises when an interest-free loan is provided by a company to a substantially related concern in shareholding. The issue was whether the...

Works contract service - zero rated supply - deemed sale or not - Section 2(39) uses the expression “includes”. But what has been brought within the inclusive definition...

The case pertains to the valuation of imported goods and the inclusion of royalty payments for determining the transaction value. The key points are: The transaction...

The Trade Notice amends the Interest Equalisation Scheme (IES) by introducing caps on the annual net subvention amount per IEC. For the financial year starting...

Quick Updates: