Royalty payment to non-UK entities without APA/MAP; transfer pricing adjustment remitted to TPO for arm's length determination.

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....The Assessee paid royalty to non-UK entities without entering into an Advance Pricing Agreement (APA) or Mutual Agreement Procedure (MAP) proceedings for the assessment year 2017-18. However, the Assessee entered into MAP with UK entities. The issue pertains to transfer pricing adjustment on royalty paid to non-UK entities. The Tribunal remitted the matter to the Assessing Officer/Transfer Pricing Officer to determine the arm's length price, consistent with its earlier decision for the assessment year 2013-14 involving a similar issue with an associated enterprise in Germany. The Assessee's appeal was partly allowed for statistical purposes.....