TATA CUMMINS PRIVATE LIMITED,PUNE vs. THE DCIT CIRCLE-1-JAMSHEDPUR AND THE ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, NFAC, DELHI, JAMSHEDPUR

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaytata Cummins Private Limited, D.C.I.T., Cummins India Office, Tower-A, 7Th Circle-1, Vs. Floor, Survey No. 21, Balewadi, Pune, Jamshedpur. Maharashtra. Pan No. Aaact 6353 L Appellant/ Assessee Respondent/ Revenue

92B of the Act. 10. Objection 9 -Expenditure on in-house R&D is not a service to Cummins Inc. and is incurred solely for the benefit of TCPL 10.1 Cummins Inc. provides TCPL the technical know-how (i.e. methodology) to produce certain category (like Cummins B, ISBe, ISLe) of engines. However, the engines produced by TCPL, using the technology