https://www.taxtmi.com/caselaws?id=194989 The Tribunal upheld the CIT(A)'s decision on all issues, rejecting the revenue's grounds of appeal and dismissing the appeal. The CIT(A) had correctly applied current year data for comparability analysis in the case of Arm's Length Price (ALP) and deemed the royalty payment as revenue expenditure. The Tribunal found that the expenses on warranty, advertisement, purchase of software, and recruitment/training were revenue in nature and deductible. Additionally, the Tribunal held that inter-corporate deposits did not constitute deemed dividend. en-us Tue, 30 Apr 2013 00:00:00 +0530 Tue, 10 Oct 2017 11:56:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=194989 The Tribunal upheld the CIT(A)'s decision on all issues, rejecting the revenue's grounds of appeal and dismissing the appeal. The CIT(A) had correctly applied current year data for comparability analysis in the case of Arm's Length Price (ALP) and deemed the royalty payment as revenue expenditure. The Tribunal found that the expenses on warranty, advertisement, purchase of software, and recruitment/training were revenue in nature and deductible. Additionally, the Tribunal held that inter-corporate deposits did not constitute deemed dividend. Case-Laws Income Tax Tue, 30 Apr 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=194989