Royalty Deduction Denied for Aquafina Franchisee; No Trademark Infringement Evidence Found by Revenue Authorities.

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....Disallowance of Royalty paid u/s 37(1) - assessee is a franchisee bottler for the brand Aquafina owned by the franchisor PepsiCo India Holdings Pvt. Ltd. - there is no material available on record to show that the assessee has infringed the trademark registered in the name of PepsiCo Inc. - No basis in the submissions of the Revenue in denying the claim of deduction of Royalty paid by the assessee to Pepsi Foods Private Ltd during the year under consideration. - AT....