https://www.taxtmi.com/caselaws?id=364906 The ITAT upheld the CIT(A)'s decision to delete the addition made by the TPO, confirming that the taxpayer was not considered a contract manufacturer for its associated entity. The ITAT found that the taxpayer's business operations were not reliant on exports to the associated entity, and the royalty payments were deemed justified. The appeal of the Revenue was dismissed, and the decision of the CIT(A) was upheld based on the analysis of the facts and relevant judicial precedents. en-us Fri, 03 Aug 2018 00:00:00 +0530 Mon, 06 Aug 2018 23:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=364906 The ITAT upheld the CIT(A)'s decision to delete the addition made by the TPO, confirming that the taxpayer was not considered a contract manufacturer for its associated entity. The ITAT found that the taxpayer's business operations were not reliant on exports to the associated entity, and the royalty payments were deemed justified. The appeal of the Revenue was dismissed, and the decision of the CIT(A) was upheld based on the analysis of the facts and relevant judicial precedents. Case-Laws Income Tax Fri, 03 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=364906