Addition to income on account of reversal of provision for royalty deleted in Skoda Auto case

Advocate Akhilesh Kumar Sah DCIT Vs. M/s. Skoda Auto A.S. (ITAT Pune) In this case, one of the ground raised by Revenue was whether in the facts and circumstances of the case, the Dispute Resolution Panel was right in directing AO to delete proposed addition on account of reversal of provision for Royalty of Rs.1,39,18,474/-, though the assessee had failed to reconcile the figures in this regard with the payer’s books of account. Briefly, in the facts of the case, the assessee was subsidiary of Volkswagen AG. The Volkswagen Group was one of the world’s leading automobile manufacturers and...