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ITAT Delhi directed TPO to accept Advance Pricing Agreement parameters for royalty adjustment
Case Law Details
- Case Name
- JCB India Ltd. Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2013-14
- Courts
- All ITAT, ITAT Delhi
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JCB India Ltd. Vs ACIT (ITAT Delhi)
ITAT Delhi held that Transfer Pricing Adjustment in respect of transaction of payment of royalty is set aside and Transfer Pricing Officer [TPO] is directed to accept the parameters of determination of compensation as accepted in Advance Pricing Agreement [APA].
Facts- JCB India Limited (‘JCB India’ or ‘Appellant’) is a subsidiary of J.C. Bamford Excavators Ltd., U.K (‘JCB UK’) and is engaged in manufacturing and trading of excavators/loaders/construction equipment, spares and components. Assessee has claimed that since establish...






