Margin accepted at ALP hence no separate benchmarking of royalty payment required

DCIT Vs Toyota Kirloskar Motor Pvt Ltd (ITAT Bangalore)

ITAT Bangalore held that no separate benchmarking of royalty payment required when the margin is accepted to be at arms length price (ALP) by the TPO. Thus, appeal of the revenue dismissed.

Facts- The assessee is a subsidiary of Toyota Motor Corporation, a company incorporated under the laws of Japan. The assessee filed their return of income on 29/09/2008 declaring a total income of Rs. 365,08,48,458/-. Thereafter, the return was processed u/s. 143(1) of the Act. Later on a reference u/s. 92CA of the

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