Other method in rule 10AB is most appropriate method in case of royalty transactions

ASB International Pvt Ltd Vs Additional Income Tax Officer (ITAT Mumbai) ITAT Mumbai held that “other method” provided in Rule 10AB r.w.s. 92C (1) would be a good substitute for CUP as there is lack of reliable comparables in case of royalty transactions as royalty payments have been made for unique intangibles Facts- The assessee is a wholly owned subsidiary of Nissei ASB Machine Co. Ltd. and was set up as a 100% Export Oriented Unit (EOU). It is engaged in the manufacturing of injection stretch blow molding machines, molds and parts, components, and subassemblies of machines and ...