No adjustment for disallowance of license fees and management charges U/s. 44C of Income Tax Act 1961

Brief Facts: Lloyd’s Register U K is having a subsidiary in the name Lloyd’s Register Asia UK, which has an Indian branch in India. In other words, the assessee is an Indian branch of Lloyd’s Register Asia UK, which in turn is a subsidiary of Lloyd’s Register UK. The main holding company is into the business of survey and inspection of ships, industrial inspection activity and drawing appraisal. Earlier Lloyd’s Register UK was operating in India through its branch. From the relevant financial year (i.e. A Y 2005-06), it floated a subsidiary company, Lloyd’s ...