2,201 results for “transfer pricing”+ Section 43(6)clear
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In the result, assessee’s appeal is partly allowed
Bench: Shri Saktijit Dey & Shri Rajesh Kumar
6. Justifying the change in the method of royalty payment from net sales to gross sales, the assessee submitted that the licensor always intended to collect royalty on gross sales. However, it was not able to do so prior to 2009 owing to the restrictions in the Foreign Direct Investment policy (FDI) prevalent at that time which required net sales