Royalty for use of Dabur brand by Overseas Subsidiary is an international transaction and TP Adjustment can be applied

Dabur India Ltd. Vs. Pr. CIT (Delhi High Court) 1. The assessee in its appeal under Section 260A urges that the findings of the lower authorities affirmed by the Income Tax Appellate Tribunal (ITAT) are erroneous. It is urged specifically that the attribution of an international transaction, is premised upon the existence of one under Section 92B, calling for adjustment under Section 92C and in the present case, in fact, there was no such transaction; furthermore it is contended that in the absence of any comparable transaction between unrelated third parties or an unrelated third party and th...