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Bad-Debts Cannot be relevant factor to determine ALP of royalty transaction between licensor & licensee
Case Law Details
- Case Name
- The Commissioner of Income Tax – 10 Vs CA Computer Associates India Pvt. Ltd. (Bombay High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All High Courts, Bombay High Court
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Bombay High Court Ruling in case of Commissioner of Income Tax – 10 vs. M/s CA Computer Associates India Private Limited [ITA No.20 of 2011 Asst. Year 2006-2007]
Gist: Bad-debts cannot be the relevant factor to determine the arm’s length price of the royalty transaction between the licensee and the licensor.
Facts:
CA Computers India Private Limited (‘the respondent’) had entered into a Software Distribution Agreement with CA Management Inc. (‘CAMI USA’) where under the respondent was appointed as a distributor of the products of CAMI USA in India. Under the ag...
