2019 (8) TMI 516

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....espondent Through: Ms. Kavita Jha & Mr. Vaibhav Kulkarni, Advocates. O R D E R CM Appl. No. 50730/2018 (delay) 1. For the reasons stated in the application, the delay of 12 days in re-filing the appeal is condoned and the application is disposed of. ITA No. 1384/2018 2. The Revenue is in appeal against an order dated 17th April, 2018 passed by the Income Tax Appellate Tribunal in IT....

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.... of the Income-tax Act, 1961 even when all the functions with regard to creation of intangibles were carried out in India for which arm's length remuneration was not paid? 2.4 Whether the Ld. ITAT erred in deleting the transfer pricing adjustment on account of AMP expenditure by ignoring a fact that functions performed, assets used and risk assumed by the Assessee in creating market for i....

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.... India Pvt. Ltd. v. CIT (Supra)? 4. Ms. Kavita Jha, learned counsel appearing for the Assessee, contends that all of the above questions stand answered in favour of the Assessee and against the Revenue by the orders of this Court for the earlier AYs. She has placed before the Court the relevant orders in this regard. 5. As regards the disallowance on account of payment of Royalty on sales ma....