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Income Tax

ITAT Delhi directed TPO to accept Advance Pricing Agreement parameters for royalty adjustment

Case Law Details

Case Name
JCB India Ltd. Vs ACIT (ITAT Delhi)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2013-14
Advertisement JCB India Ltd. Vs ACIT (ITAT Delhi) ITAT Delhi held that Transfer Pricing Adjustment in respect of transaction of payment of royalty is set aside and Transfer Pricing Officer [TPO] is directed to accept the parameters of determination of compensation as accepted in Advance Pricing Agreement [APA]. Facts- JCB India Limited (‘JCB India’ or ‘Appellant’) is a subsidiary of J.C. Bamford Excavators Ltd., U.K (‘JCB UK’) and is engaged in manufacturing and trading of excavators/loaders/construction equipment, spares and components. Assessee has claimed that since establish...
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