Royalty Rate for Associated Enterprises Limited to 0.75% u/s 92B of Income Tax Act, Overruling 2% Decision.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Chargeability of Royalty from Associated Enterprises (AEs) - International transaction as contemplated u/s 92B - The facts in the present assessment is also similar and no distinguishing facts were pointed out by the Ld. DR or the Ld. AR, therefore, the finding of the CIT(A) that royalty @ 2% is to be charged from AE, appears to be not correct. Therefore, following the earlier years order by the Tribunal, we are restricting the said royalty to 0.75% in case of AE - AT....