https://www.taxtmi.com/caselaws?id=208573 The Tribunal ruled in favor of the appellant, overturning the decision to disallow the royalty payment to the Associated Enterprise. The Tribunal found that the appellant justified the royalty payment under the Comparable Uncontrolled Price method and was not solely a contract manufacturer for the AE. Additionally, the Dispute Resolution Panel-II's disallowance of a 5% deduction under section 92C(2) was upheld, resulting in an addition to the appellant's total income. en-us Fri, 16 Dec 2011 00:00:00 +0530 Thu, 21 Apr 2016 10:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208573 The Tribunal ruled in favor of the appellant, overturning the decision to disallow the royalty payment to the Associated Enterprise. The Tribunal found that the appellant justified the royalty payment under the Comparable Uncontrolled Price method and was not solely a contract manufacturer for the AE. Additionally, the Dispute Resolution Panel-II's disallowance of a 5% deduction under section 92C(2) was upheld, resulting in an addition to the appellant's total income. Case-Laws Income Tax Fri, 16 Dec 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208573