M/S.US TECHNOLOGY RESOURCES P. LTD,TRIVANDRUM vs. THE ACIT, TRIVANDRUM
In the result, the appeal for assessment year 2011-2012
ITA 134/COCH/2016[2011-12]Status: DisposedITAT Cochin11 May 2018AY 2011-12
Bench: Shri Chandra Poojari, Am & Shri George George K, Jm
For Appellant: Sri.Raghunathan S., AdvocateFor Respondent: Sri. Santham Bose, CIT-DR
Section 144C(5)Section 190Section 194JSection 234BSection 40Section 92C(3)
disallowance of the brand fee royalty payment while determining the ALP. Accordingly, the substantial questions of law are answered in the affirmative and in favour of assessee and against the Revenue.
The appeals are accordingly dismissed with no order as to costs"'.
15. On the other hand, the learned
Departmental
Representative relied on the order of the lower authorities
