Allowing the appeal of the assessee the Court held that ; as royalty paid was already forming part of operating cost, there was no necessity of separately benchmarking royalty .Matter was to be remanded back for readjudication. ( AY. 2011-12, 2012-13)
Kaypee Electronics & Associates (P.) Ltd. v. DCIT (2018) 256 Taxman 163 (Karn)( HC)
S. 92C : Transfer pricing – Arm’s length price – Royalty paid was already forming part of operating cost, there is no necessity of separately benchmarking royalty.-Matter remanded to Tribunal ]