https://www.taxtmi.com/caselaws?id=176687 The Tribunal concluded that the assessee was an independent manufacturer, not a contract manufacturer, based on its assets and sales. It allowed the royalty payment to SCCL at 5%, emphasizing it was for technical knowhow. The Tribunal deemed the reopening of assessment under section 147 invalid as the original reason was not pursued. It directed the AO to allow the royalty payments and highlighted the importance of assessing the actual business profile over relying solely on the TP report. en-us Wed, 07 Nov 2012 00:00:00 +0530 Sat, 03 Jun 2017 17:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=176687 The Tribunal concluded that the assessee was an independent manufacturer, not a contract manufacturer, based on its assets and sales. It allowed the royalty payment to SCCL at 5%, emphasizing it was for technical knowhow. The Tribunal deemed the reopening of assessment under section 147 invalid as the original reason was not pursued. It directed the AO to allow the royalty payments and highlighted the importance of assessing the actual business profile over relying solely on the TP report. Case-Laws Income Tax Wed, 07 Nov 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=176687