Just a moment...
Press 'Enter' to add multiple search terms. Rules for Better Search
When case Id is present, search is done only for this
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
Don't have an account? Register Here
<h1>Appeal Dismissed: ITAT's Decision on Royalty & Technical Fees Adjustments Upheld; DRP Directive Binding for AY 2010-11.</h1> <h3>PRINCIPAL COMMISSIONER OF INCOME TAX, DELHI Versus M/s WOODWARD INDIA PVT. LTD</h3> The HC dismissed the appeal by the Principal Commissioner against the ITAT order concerning adjustments to royalty and technical fees. The court upheld ... TP Adjustment - Royalty and payment of Technical fee paid by the respondent/assessee to its Associated Enterprise (AE) - HELD THAT:- Appellant, on instructions apprises us that although the aspect of royalty may have constituted the subject matter of the AYs as noticed by us hereinabove, the issue of technical know-how fee did not form the subject matter of consideration in AYs 2011-12, 2012-13 and 2013-14. We note that undisputedly in AY 2010-11, both aspects were duly examined by the DRP. The direction as framed by the DRP in terms of the statutory regime which prevails would clearly bind the Assessing Officer. No justification to entertain the instant appeal. Consequently, we see no reason to interfere with the impugned order of the ITAT. The present appeal stands dismissed on the aforesaid terms. The High Court dismissed the appeal by the Principal Commissioner challenging the ITAT order regarding royalty and technical fee adjustments. The court found no reason to interfere as the DRP's direction in AY 2010-11 binds the Assessing Officer. The appeal was dismissed.