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Ground relates to Transfer Pricing adjustment in relation to payment of royalty to the tune of Rs. 787,096,934/-This ground covers ground no. 5 to 7 of revenue’s appeal in ITA No. 529/Kol/2015, for A.Y. 2010-11, Ground no. 6 of revenue’s appeal in ITA No. 518/Kol/2016, for A.Y. 2011-12,Ground No.4a to4b of assessee's appeal in ITA No.625/Kol/2016 for A.Y.2011-12 and additional grounds raised by the assessee in A.Y. 2011-12 wherein the assessee stated that payment of royalty was subsumed in the entity level Transactional Net Margin Method (TNMM), analysis conducted by the assessee using combined transaction approach.

Shanti Prime Publication Pvt. Ltd.

Sec. 92C of Income Tax Act, 1961—Transfer Pricing—Computation of arms length price - AMP transaction does not represent the international transaction between the assessee and its AE’s as the revenue failed to bring on record any contract or arrangement between assessee and its AE for making AMP expenses for promotion of brand of its AE, therefore, in the assessee's case, the assessee company was not under any obligation to incur AMP expenses and also its parent company had no control over such decisions of RBIL and these are routine advertisement expenses, thus, AMP cannot be regarded as international transaction - RECKITT BENCKISER (I) PVT. LTD. V/s DEPUTY CIT - [2020] 81 ITR (TRIB) 577 (ITAT-KOLKATA)