Royalty expense allowable when goods are sold to Associated Enterprise on principal-to-principal basis

Honda Motorcycle and Scooters India Pvt. Ltd. Vs DCIT (ITAT Delhi)

Facts-

The appellant, Honda Motorcycle and Scooters India Pvt. Ltd., is a subsidiary of Honda Motor Company Ltd., Japan. As per the agreement, the assessee is liable to pay the royalty of goods manufactured.

Conclusion-

Royalty payment-

It is not in dispute that the goods which are ex

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