TPO adjustment towards technical know-how fees after accepting entity level margins is unsustainable
Case Law Details
Case Name : Tata Power Solar Systems Limited Vs ACIT (ITAT Bangalore)
Related Assessment Year : 2004-05
Courts :
All ITAT ITAT Bangalore
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Tata Power Solar Systems Limited Vs ACIT (ITAT Bangalore)
ITAT Bangalore held that the adjustment made by the TPO towards technical know-how fees despite accepting the entity level margins is liable to be deleted.
Facts- During the year under consideration, the assessee entered into various international transactions with its Associated Enterprises (AEs) which inter alia included payment towards technical know-how amounting to Rs.9,07,39,440.
During the course of as
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