Disallowance made of royalty paid by the assessee to CAMI USA ...

Court Rules Royalty Payments Cannot Be Reduced After Arm's Length Price Justification, Despite Customer Non-Payment Issues.

July 23, 2012

Case Laws Income Tax HC

Disallowance made of royalty paid by the assessee to CAMI USA for distribution of software products in India - Once it is accepted that the ALP of the royalty is justified, there can be no reduction in the value thereof on account of the assessee's customers failing to pay the assessee for the product purchased by them from the assessee. - HC

View Source

← Previous Next →

Disallowance made of royalty paid by the assessee to CAMI USA ...

Court Rules Royalty Payments Cannot Be Reduced After Arm's Length Price Justification, Despite Customer Non-Payment Issues.

July 23, 2012

Case Laws Income Tax HC

You may also like:

The High Court upheld the Income Tax Appellate Tribunal's (ITAT) decision regarding the applicability of Section 92(3) in determining the arm's length price for...

Scrutiny by the High Court in an appeal u/s 260A for Determination of the arm’s length price made by the Tribunal - When the determination of the arm’s length price is...

Valuation of imports from related suppliers and the inclusion or exclusion of royalty in the transaction value. The key points are: Rule 10(1)(c) of the Customs...

If the Transfer Pricing Officer did not agree to the arm's length price shown by the assessee it was open for him to determine the arm's length price by applying one of...

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...

TP Adjustment - valuation of Arms Length Price (ALP) - No Arm's Length Price is required to be determined for a transaction with specified persons in section 40A(2)(b)...

The Supreme Court upheld the validity of the Explanations to Rule 38 of the Mineral (Other than Atomic and Hydrocarbons Energy Minerals) Concession Rules, 2016 and Rule...

The case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

TP Adjustment - Adjustment in the transaction of payment of royalty - Royalty payments made by the subsidiary for using certain intangible properties and services. - The...

The ITAT held that the Transfer Pricing Officer (TPO) should consider comparables dealing in electronic products only, supported by a technical expert's certificate,...

TP Adjustment - Determination of arm’s-length price - Law does not permit the TPO or DRP to determine the arm’s length price on estimation or adhoc basis. - Accordingly...

Valuation of imported goods - inter-se relation having any influence on the transaction value of imports, or not - If the price declared was at arm’s length, then...

Transfer pricing adjustments, selection of the most appropriate method (MAM), benchmarking approach (aggregation or segregation), factual rendering of services, arm's...

Transfer pricing adjustment - the addition made by the TPO by determining arm’s length price of royalty on export at nil is deleted. There is no justification for...

The Income Tax Appellate Tribunal (ITAT) held that in determining the arm's length price for transfer pricing adjustments, three companies (MOIAPL, LCAPL, and MOEPAPL)...

Quick Updates: