Disallowance made of royalty paid by the assessee to CAMI USA...

Disallowance made of royalty paid by the assessee to CAMI USA for distribution of software products in India - Once it is accepted that the ALP of the royalty is justified, there can be no reduction in the value thereof on account of the assessee's customers failing to pay the assessee for the product purchased by them from the assessee. - HC