TP Adjustment of ₹166.09 Crore for Non-UK Royalties payment Remanded back to TPO

JCB India Ltd. Vs DCIT (ITAT Delhi) Reassessment of ₹166.09 Crore TP adjustment for royalty payments to Non-UK Entities in AY 2017-18 was remanded back to TPO Conclusion: Reassessment of JCB India’s transfer pricing ( TP ) adjustment of Rs. 166.09 crore for royalty payments made to non-UK associated enterprises ( AEs ) for the assessment year 2017-18 was remanded back to TPO for determining the arm’s length price ( ALP ) for non-UK entities as assessment year 2017-18 was not covered within APA period. Held: Assessee was a subsidiary of J.C. Bamford Excavators Ltd. ( UK ), which manufactu...