In the result, the appeals of the revenue are dismissed and the appeals of the assessee are allowed
Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.1333/Kol/2017 ("नधा"रणवष" / Assessment Year:2008-09)
TP Document Study Report (Refer page no. 107-121 of the Paper Book). Thus ld counsel submits that the assessee pays royalty for on-going, ever-flowing and comprehensive bouquet of services (such as technical support, information, upgrades, use of trade-marks, patents, Vesuvius brand etc.). The benefits received by the assessee due to its association with AEs for outweighs