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Home Highlights March 2020 Year 2020 This

TP Adjustment - Technical know-how fees paid by Appellant to its ...


Transfer Pricing Dispute: TPO's Benefit Test on Technical Know-How Fees Violates Rule 10B and 10AB.

March 30, 2020

Case Laws     Income Tax     AT

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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