https://www.taxtmi.com/caselaws?id=213791 The Tribunal partly allowed the appeal in a tax case involving issues of transfer pricing, taxability of receipts as royalty, and jurisdiction under section 263 of the Income-tax Act. The Tribunal found that the Assessing Officer's failure to refer the valuation of international transactions to the Transfer Pricing Officer had been rectified. It concluded that the taxability of receipts should be assessed under section 44BB, not as royalty under section 9(1)(vi). The Tribunal held that the Direction of Income-tax did not conclusively establish the assessment order as erroneous, allowing the appeal in part and setting aside the Direction's order on the ground of taxability of receipts as royalty. en-us Mon, 30 Apr 2012 00:00:00 +0530 Mon, 04 Jun 2012 08:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=213791 The Tribunal partly allowed the appeal in a tax case involving issues of transfer pricing, taxability of receipts as royalty, and jurisdiction under section 263 of the Income-tax Act. The Tribunal found that the Assessing Officer's failure to refer the valuation of international transactions to the Transfer Pricing Officer had been rectified. It concluded that the taxability of receipts should be assessed under section 44BB, not as royalty under section 9(1)(vi). The Tribunal held that the Direction of Income-tax did not conclusively establish the assessment order as erroneous, allowing the appeal in part and setting aside the Direction's order on the ground of taxability of receipts as royalty. Case-Laws Income Tax Mon, 30 Apr 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=213791