Unrelated Parties’ Royalty Agreement Cannot Be Subjected to Transfer Pricing Adjustments or Section 37(1) Benchmarking
Unrelated Parties’ Royalty Agreement Cannot Be Subjected to Transfer Pricing Adjustments or Section 37(1) Benchmarking Issue Whether royalty paid by a resident assessee to an unrelated foreign entity under an arms-length trademark license agreement can be subjected to transfer pricing adjustments under Section 92A or disallowed as excessive under Section 37(1). Facts Agreement & Transaction:… Read More »