M/S Reckitt Benckiser (I) Pvt. Ltd., Kolkata vs. DCIT, Cir-12(1), Kolkata
In the result, Appeals of the assessee are partly allowed for statistical purposes whereas Appeals of the revenue are dismissed to the extent indicated above
ITA 625/KOL/2016[2011-2012]Status: DisposedITAT Kolkata17 Jun 2020AY 2011-2012
Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.404/Kol/2015 आयकरअपीलसं./Ita No.625/Kol/2016 ("नधा"रणवष" / Assessment Year: 2010-11 To 2011-12)
For Appellant: Shri Deepak Chopra, Advocate & Shri Rohan Khare, AdvocateFor Respondent: Dr. P. K Srihari, CIT(DR)
…mining the ALP. Accordingly, the substantial questions of law are answered in the affirmative and in favour of the assessee and against the Revenue. The appeals are accordingly dismissed with no order as to costs.” (ii) Frigoglass India Pvt Ltd V DCIT [2016] 180 TTJ 401(Del-trib) “9. On the issue of royalty, the Ld. AR submitted that the assessee has entered into royalty agreement with its AE - Frigoglass SAIC (Head Office) on account of receipt of ICM Technology and for use of trademark. It was submitted that CUP method could not be applied in the case as neither the AE nor the assessee have entered into simil…