2014 (8) TMI 1028

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....,31,863/-   2. Payment of Training and Testing Expenses Rs. 13,46,823/-   3. Payment of Design and Development Expenses Rs. 69,992/-   In the impugned order dated 23.08.2013, Income Tax Appellate   Tribunal has reproduced the findings and observations of the Transfer Pricing Officer, who had proceeded and recorded that the respondent- assessee had not produced evidence/documentation regarding payment of royalty and quantification/rate. No costs benefit analysis and details of other concerns or third parties were filed. The economic benefit from the alleged knowhow received was not explained.   The aforesaid analysis and summing up does not refer to payments made by the respondent-assessee by way of technical fe....

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...., the Assessing Officer passed the final assessment order dated 22.08.2012 making addition of Rs. 26,48,678/-. On further appeal before the Tribunal, the said addition has been deleted, recording as under: "8.2 Assessee filed the objections before the DRP. The DRP held that in its opinion, the payment made under head royalty was at arms length, as for the payment made under other heads, the stand taken by the TPO was approved. Thus, we find that DRP has held that the royalty payment was at arm's length which cover a substantial part of TPO?s disallowance at Rs. 1,56,43,832/-. The DRP has observed that as for the payment made under the other heads the stand taken by the TPO was approved. We find that regarding the payments made under o....