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Income Tax - Highlights / Catch Notes

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TP Adjustment - Adjustment for royalty income - maintaining of a ...


Royalty Income Exceeds Arm's Length Price; No Additional Adjustment for Brand Maintenance Needed.

January 4, 2024

Case Laws     Income Tax     AT

TP Adjustment - Adjustment for royalty income - maintaining of a brand - risky intangible - Since the assessee has offered royalty income higher than the ALP computed by applying WACC of 11.30% of the brand value, no further upward adjustment is called for. - AT

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