Citi global transfer 汇款9/26/2023 ![]() The assessee claimed expenditure relating to payment of remuneration of directors. Accordingly, it deleted the TP adjustment made.ĭQ Entertainment International Ltd v ACIT – TS-19-ITAT-2018(HYD)-TP – ITA No.441/Hyd/2017 dated Ģ. The Tribunal held that once IPR was sold and the arm’s length price of such sale was determined, the IPR became the property of AE and any subsequent transaction between AE with outsiders or outside the jurisdiction of the Indian territory did not give rise to international transaction between assessee and AE. Where the assessee had sold its IPRs to its AE in the prior years (which was benchmarked under the TP provisions) and the AE in the capacity of owner had exploited the impugned IPR in the year under review by entering into transactions with third parties, the Tribunal held that the TPO was incorrect in imputing an adjustment in the hands of the assessee contending that the economic ownership of the IPR was still with the assessee and that income earned by the AE from exploitation of IPR was in effect an international transaction between the assessee and the AE. International Transactions / Specified Domestic Transactionsġ. The Digests for the earlier periods are available hereĪ. ![]() A brief head note is given for each case. The Digest comprises of all the important judgements dealing with transfer pricing, international taxes and domestic taxation laws. ![]() Link to download this article in pdf format is at the bottom
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