https://www.taxtmi.com/caselaws?id=242428 ITAT Mumbai followed the assessee's own prior transfer pricing rulings and accepted that licence fees paid at 3% of turnover for use of intangible and intellectual property were at arm's length, resulting in deletion of the adjustment. On the dividend taxation ground concerning Article 10 of the India-Switzerland DTAA, the Tribunal found that the first appellate authority had not adjudicated the issue and restored it for fresh consideration in accordance with law. The appeals were thus partially allowed, with relief granted on the licence fee issue and remand ordered on the dividend ground. 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 ITAT Mumbai followed the assessee's own prior transfer pricing rulings and accepted that licence fees paid at 3% of turnover for use of intangible and intellectual property were at arm's length, resulting in deletion of the adjustment. On the dividend taxation ground concerning Article 10 of the India-Switzerland DTAA, the Tribunal found that the first appellate authority had not adjudicated the issue and restored it for fresh consideration in accordance with law. The appeals were thus partially allowed, with relief granted on the licence fee issue and remand ordered on the dividend ground. Case-Laws Income Tax Wed, 22 May 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=242428