Price of bank note paper purchased by assessee from DLRI was an ALP which included cost associated with know how and design

De La Rue Currency & Security Print Limited Vs Commissioner of Domestic Taxes Conclusion: Since Respondent had pointed out that all security features relating to the banknotes were already incorporated on the paper purchased by assessee from DLRI to be used to print the banknotes under the contract that assessee with CBK thus, any technical support or IP provided by DLRI to assessee was fully compensated in the price charged by DLRI for the paper on which the banknotes were to be printed. Held: Assessee was a limited liability company incorporated in Kenya and was part of the De La Rue Pl...