2019 (8) TMI 1810

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....s a wholly-owned subsidiary of Benetton International NV, Netherlands which in turn is a subsidiary of Benetton Group SPA, Italy. Assessee is engaged in the business of production and sale of readymade garments in the name and style of 'Benetton' in India. 3. For the Assessment Year 2011-12, assessee filed their return of income on 30.11.2011 declaring 'nil' income after setting off the brought forward losses to the tune of Rs. 67,04,642/-under normal provisions of the Income Tax Act, 1961 (for shor t "the Act"). 4. During the Financial Year 2010-11, the assessee had entered into the international transaction and paid a sum of Rs. 13,74,48,935/-towards royalty and for benchmarking the said transaction the assessee employed the CUP met....

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....sessee had been using the technical know-how developed by the associated enterprise in its manufacturing activities on account of use of trademark and technical know-how. Further Ld. CIT(A) followed the decision of the Tribunal in assessee's own case for the Assessment Year 2006-07 which was followed by the Ld. CIT(A) for the Assessment Years 2007-08 to 2009-10. Ld.AR also produced copy of the order dated 27/10/2017 in assessee's own case for the Assessment Year 2009-10 in ITA No. 4229/Del/2014 wherein the identical issue was dealt with and answered in favour of the assessee. 8. We have gone through the record in the light of the submissions made on either side. Having considered the facts in their entirety, Ld. CIT(A) found that the ent....