ITAT v Adopts CBDT-Approved APA Rate for Royalty and FTS ALP

Bellsonica Auto Component India Private Limited Vs ACIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi, partly allowed the assessee’s appeal for Assessment Year 2014-15 by restricting the transfer pricing adjustment relating to royalty and fees for technical services (FTS) to the rate accepted by the Central Board of Direct Taxes (CBDT) under a Unilateral Advance Pricing Agreement (UAPA). The Tribunal directed the Assessing Officer (AO) to apply a rate of 1.9% of net sales instead of sustaining the adjustment determined by the Transfer Pricing Officer (TPO). The assessee had fi...