2020 (2) TMI 1704

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..... SHARMA, A.M.  This is the appeal filed by the assessee against the order of the ld. CIT(A)-15, Mumbai dated 19/03/2014 for the A.Y. 2007-08 in the matter of order passed U/s 143(3) of the Income Tax Act, 1961 (in short, the Act). 2. The only issue for determination is pertaining to payment of trademark royalty of Cadbury Schweppes Overseas Limited (in short, CSOL) and the transfer pricin....

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.... purpose only to decide this issue. 4. We have considered the rival contentions and carefully gone through the orders of the authorities below and found that this Tribunal in assessee's own case for A.Y. 2006-07 in ITA No. 1512/Mum/2013 vide order dated 28/11/2018 considered this issue as under: "..... 39. On going through the records and the orders of the revenue authorities, we find that in s....

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....t is paying a lesser amount, if the payments are compared with the payments towards trademark usage, by the other group companies using the Brand Cadbury in other parts of the world. On the other hand, if we examine the argument taken by the TPO with regard to OECD guidelines. On this point the assessee "s payment is coming to a lesser figure, as discussed in detail by the CIT(A). .................