Tribunal held that there was no separate value of international transaction of royalty for use of licensed trademark and tribunal held in earlier year that it was payment of inseparable royalty for use of both licensed information and licensed trademarks. Accordingly the addition is held to be not justified. (AY. 2008 -09)
Maruti Suzuki India Ltd. v. ACIT (2018) 191 TTJ 148 (Delhi)(Trib.)
S. 92C : Transfer pricing-Arm’s Length Price—royalty for use of brand name— Adjustments held to be not justified.