TP Adjustment relating to receipt of brand royalty from AE deleted as brand not owned by assessee

Tata Consultancy Services Limited Vs DCIT (ITAT Mumbai) ITAT Mumbai held that the fee paid by the assessee i.e. Tata Consultancy Services towards the brand to Tata and Sons Ltd. is not capital in nature for the reason that the brand is not owned by the assessee. Hence, there cannot be any TP adjustment towards the amount that ought to have been received by the assessee towards brand royalty. Facts- The assessee is a company engaged in business of export of computer software providing e-solutions, BPO activities and other management consultancy activity. The case was selected for scrutiny and t...