Transfer pricing and licence fee disputes raised no question of law after prior disposal on the same issue.

The dispute concerned deletion of additions relating to variable licence fee treated as revenue expenditure and amortised under section 35ABB, along with transfer pricing adjustments for arm's length price and notional interest. The Court noted that the appeal had been admitted, but no question of law was found to arise because the same issue had already been disposed of for another assessment year. The matter was therefore directed to be listed as a regular matter.

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Issues: Whether the deletion of the addition relating to variable licence fee claimed as revenue expenditure and amortised under section 35ABB of the Income-tax Act, 1961 was justified; whether the deletion of the amount added by way of adjustment in the determination of Arm's Length Price was justified; and whether the deletion of the notional interest included in the Arm's Length Price determination was justified.

Outcome: The appeal was admitted, but no question of law was held to arise in view of the Court's earlier disposal of the same issue for another assessment year, and the matter was directed to be listed as a regular matter.

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