Royalty Expenses Allowed as Revenue Expenditure from Assessment Year 2007-08; No Adverse Reference by Transfer Pricing Officer.

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....Disallowance of royalty expenses - allowable revenue expenses - It is only in Assessment Year 2005-06, the said payment of royalty has not been allowed in the hands of the assessee. In all the later years, starting from Assessment Year 2007-08, the royalty has been allowed as revenue expenditure in the hands of the assessee - Even the TPO had not made any adverse reference in his order u/s 92CA(3) - Claim of the assessee allowed - AT....