Case Law Details
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 the largest car maker in Europe. The assessee was nonresident company based in Czech Republic, wherein Skoda developed manufactured and marketed passenger cars throughout the world. The assessee company had subsidiary in India i.e. Skoda Auto India Pvt. Ltd., which was engaged in assembly, marketing and sale of motor vehicles, parts and accessories. For the year under consideration, the assessee filed return of income declaring total income of Rs. 44,47,30,190/-. The case of assessee was selected for scrutiny. From the details furnished by the assessee, the AO noted that during the year under consideration, the assessee had received certain amounts from Skoda Auto India Pvt. Ltd. (SAIPL) and Volkswagen Group Sales India Pvt. Ltd. and Volkswagen India Pvt. Ltd.
Please become a Premium member. If you are already a Premium member, login here to access the full content.
