TP Adjustment - The product licenses were held by the AE who was ...

Product Licenses Managed by AE; Assessee Handles Non-AE Sales Expenses as per Technical Agreement with FDC-UK.

December 15, 2021

Case Laws Income Tax AT

TP Adjustment - The product licenses were held by the AE who was also responsible for maintenance of the product licenses. The manufacturing was done in strict adherence to Product License and the labeling on products was of assessee’s AE. The same is evident from Technical agreement (page no. 342-356 of the Paper Book) between the assessee and FDC-UK (AE). In case of non-AE sales, these expenses are to be borne by the assessee, which fact remains undisputed before us. Therefore, the adjustment of this component has rightly been allowed by Ld. CIT(A). - AT

View Source

← Previous Next →

TP Adjustment - The product licenses were held by the AE who was ...

Product Licenses Managed by AE; Assessee Handles Non-AE Sales Expenses as per Technical Agreement with FDC-UK.

December 15, 2021

Case Laws Income Tax AT

You may also like:

TP adjustment on account of reimbursement of seafarer expenses - Revenue has only doubted the genuineness of the alleged reimbursement of expenses made by the assessee...

TPA - Adjustment of interest for delayed realization of sale from AE - when the assessee is not charging any interest from non AE then there is no case made out by the...

Addition towards Licence expenses - The invoice value was shown as its income and the amount paid to its AE was shown as Licence fee expenditure in its Annual accounts....

TP Adjustment - Recovery of expenses represent expenses incurred by the assessee company on behalf of AE towards Bid bond expenses. These expenses were also recovered by...

Addition of sales tools expenses u/s 37 - the logic given by the coordinate bench equally applies to the sales tool expenses also. The above decision was also followed...

TP adjustment made in respect of provision of back office services - In any case, we find the main grievance of the ld. DRP seems to be that AE revenue is only ₹...

Cash credit u/s 68 r.w.s. 115BBE - cash deposit during demonetization period - assessee's failure to maintain books of accounts u/s 44AD. Held that where exemption from...

Royalty u/s. 91 (vi) OR Business income - sale of software products/ licenses - the said amount received by the assessee is normal business income of the assessee on...

Assessment u/s 153C - disallowance made u/s 37. Assessing Officer observed no supporting evidence for claimed expenses furnished by assessee and non-cooperation during...

The assessee, a non-resident corporate entity incorporated in Austria, earned income from the sale of software licenses. The Assessing Officer (AO) computed the profit...

The CESTAT held that a "deemed sale" under Article 366(29A)(d) of the Constitution had occurred when the appellant granted the right to use the brewery license to...

TDS u/s 195 - software expenses - the arrangement of the assessee company with its AE is of purchase of computer software at agreed price i.e. sale price to the Indian...

The assessee, engaged in the business of shares and securities, claimed administration expenses, including Portfolio Management Service (PMS) expenses, against capital...

Disallowing the challan paid in the name of one employee & disallowing the subvend fee paid - CIT-A deleted the addition - as submitted assessee has obtained liquor vend...

Research and Development expenses (R&D Expenses) - Allowability of expenses u/s 35(2) - The expenses are not covered u/s 35(2) - The assessee has not claimed the same...

Quick Updates: