https://www.taxtmi.com/caselaws?id=242428 The Tribunal ruled in favor of the appellant for the assessment years 2004-05 and 2005-06, setting aside the lower Arm's Length Price (ALP) rates determined by the Transfer Pricing Officer (TPO) for license fees paid to its associated enterprise (AE). The Tribunal upheld the 3% rate of license fees as ALP, citing precedent. For the assessment year 2005-06, the Tribunal directed acceptance of the 3% payment as ALP and remanded the issue of tax rate on dividends under the India Switzerland Double Taxation Avoidance Agreement back to the Commissioner of Income Tax (Appeals) for proper consideration. en-us Wed, 22 May 2013 00:00:00 +0530 Wed, 15 Jan 2014 10:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=242428 The Tribunal ruled in favor of the appellant for the assessment years 2004-05 and 2005-06, setting aside the lower Arm's Length Price (ALP) rates determined by the Transfer Pricing Officer (TPO) for license fees paid to its associated enterprise (AE). The Tribunal upheld the 3% rate of license fees as ALP, citing precedent. For the assessment year 2005-06, the Tribunal directed acceptance of the 3% payment as ALP and remanded the issue of tax rate on dividends under the India Switzerland Double Taxation Avoidance Agreement back to the Commissioner of Income Tax (Appeals) for proper consideration. Case-Laws Income Tax Wed, 22 May 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=242428