ITAT directs Reassessment of JCB India’s ₹166.09 Crore TP Adjustment for Royalty Payments to Non-UK Entities in AY 2017-18 [Read Order]

Citing precedents where MAP or APA didn't apply, the ITAT remanded the TP adjustment to the TPO to reassess ALP for non-UK entities
By Kavi Priya - On October 18, 2024 10:28 am - 2 mins read
ITAT - ITAT Delhi - Reassessment of JCB - Royalty Payments to Non UK Entities - ITAT directs reassessment - Royalty payments TP dispute - Taxscan

The Delhi Bench of Income Tax Appellate Tribunal ( ITAT ) directed the reassessment of JCB India’s transfer pricing ( TP ) adjustment of Rs. 166.09 crore for royalty payments made to non-UK associated enterprises ( AEs ) for the assessment year 2017-18. JCB India Limited, the assessee is a subsidiary of J.C. Bamford Excavators…

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