Dismissing the appeal of the revenue the Court held that the Transfer Pricing Officer cannot examine commercial expediency. Royalty payable under licence agreement. No question of law arose regarding disallowance on account of royalty paid by assessee to associated enterprises. Order of Tribunal affirmed. (AY. 2016-17)
PCIT v. Sony India Pvt. Ltd [2024] 167 taxmann.com 549 ( /(2025) 477 ITR 576 (Delhi)(HC)
S. 92C : Transfer pricing – Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Entertainment business- Royalty Payment-Transfer Pricing Officer cannot examine commercial expediency. Royalty payable under licence agreement. No question of law arose regarding disallowance on account of royalty paid by assessee to associated enterprises. Order of Tribunal affirmed. [S. 9(1)(vi), 260A]
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