https://www.taxtmi.com/caselaws?id=353135 The Tribunal upheld the CIT(A)'s decision to set aside the TPO's adjustments to royalty payments for assessment years 2003-04 and 2005-06. It emphasized the consistency of royalty payments across years, the original independent agreement, and RBI approval, concluding that the payments were at arm's length price. The Tribunal referenced precedents to support its decision. The Revenue's appeal was dismissed, affirming the CIT(A)'s approach, which indirectly applied the principle of res judicata, even though formally inapplicable to income tax proceedings. en-us Mon, 11 Dec 2017 00:00:00 +0530 Thu, 28 Dec 2017 08:05:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=353135 The Tribunal upheld the CIT(A)'s decision to set aside the TPO's adjustments to royalty payments for assessment years 2003-04 and 2005-06. It emphasized the consistency of royalty payments across years, the original independent agreement, and RBI approval, concluding that the payments were at arm's length price. The Tribunal referenced precedents to support its decision. The Revenue's appeal was dismissed, affirming the CIT(A)'s approach, which indirectly applied the principle of res judicata, even though formally inapplicable to income tax proceedings. Case-Laws Income Tax Mon, 11 Dec 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=353135