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ITAT Orders Fresh Benchmarking of Royalty Payments, Prefers Traditional Methods Over TPM
Case Law Details
- Case Name
- Marks and Spencer (India) Private Limited Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2018-19
- Courts
- All ITAT, ITAT Delhi
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Marks and Spencer (India) Private Limited Vs ACIT (ITAT Delhi)
ITAT: Orders fresh benchmarking of royalty payments, prioritizing traditional methods over the transactional profit method
Facts:
The assessee “Marks and Spencer (India) Private Limited” was incorporated on 01.04.2005 and is a wholly owned subsidiary of Marks and Spencer Investments Pte. Ltd., Singapore (“M&S Singapore”). The assessee is engaged in the wholesale business of procuring and selling branded apparel and accessories, including leather products and toiletries. In addition to its trading activ...
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