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1. 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...

2. Nature of expenses - payment of royalty - acquisition of intangible asset - the appellate authorities, while deleting the disallowances made by the assessing officer,...

3. Accrual of income in India - PE in India or not? - use or right to use brand name/trade mark - the receipts cannot be treated as royalty under Article 12(3)(a) of the...

4. Royalty payment to FCC Co. Ltd., Japan - revenue or capital expenditure - Either having 50% control or 100% control that will not change the colour of nature of...

5. Royalty payment - revenue expenditure or capital expenditure - payment is purely revenue in nature, as they provide for payment of license fee for manufacture and sale...

6. Disallowance of expenditure as capital expenditure being 25% of royalty amount paid - it cannot be said that the Sweden Company had relinquished its command over the...

7. 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...

8. Disallowance of cash payments in excess of prescribed limit u/s. 40A(3) - even though few payments is covered u/s. 40A(3) of the Act, because of peculiar nature of...

9. Disallowance of royalty expenses - allowable revenue expenses - It is only in Assessment Year 2005-06, the said payment of royalty has not been allowed in the hands of...

10. The assessee, a sole proprietor running a petrol pump allotted by BPCL, deposited unexplained cash in the current bank account. The AO invoked Section 69A and made an...

11. Royalty of 1.75% paid on yeast manufactured in India and sold using technical knowhow provided by foreign supplier is not includable in value of imported yeast culture...

12. Disallowance of freight expenditure u/s 40A(3) paid in Cash - As enhanced limit of ₹ 35,000/- is applicable for the payment to the transport operators and in other...

13. Addition u/s 40A(3) - expenditure paid at various project sites in cash mode - unexplained expenditure - We invoke stricter interpretation of the impugned disallowance...

14. Income accrued in India - consideration received by the assessee for sale of software cannot be treated as royalty under the provision of section 9(1)(vi) of the Act as...

15. Disallowance u/s 40A(3) - Cash payment - Section 40A(3) is not applicable when the net profit rate was applied by the AO and once a net profit rate is applied the...