Adjustment of notional royalty, for the know how transferred to Indian company, against the purchase consideration for the products manufactured for t

Court: Bangalore bench of the Income-tax Appellate Tribunal Citation: Robert Bosch GmbH Vs. ACIT [2010-TII-149-ITAT-BANG-INTL] Brief : Recently, the Bangalore bench of the Income-tax Appellate Tribunal (the Tribunal) in the case of Robert Bosch GmbH v. ACIT [2010-TII-149-ITAT-BANG-INTL] (the taxpayer) while rejecting the contention of the tax department held that the taxpayer is not expected to make royalty income with reference to the sale effected to it by an Indian company, when the know how for manufacture of the same is supplied by the taxpayer itself. Accordingly, such notional royalty...