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No TP additions towards royalty if assessee didn’t charge any sum over & above from selling price from AEs

September 29, 2020[2020] 119 421 (Bangalore - Trib.)

TRANSFER PRICING : Where assessee obtained approval for marketing its products, however, exported finished goods to AEs located in respective countries which in turn marketed goods and assessee had not collected any amount over and above selling price either from domestic customers or from non-AEs, it could not be said that AEs had exploited product registration/license obtained by assessee from various Governments and accordingly royalty TP-adjustment was to be deleted

TRANSFER PRICING : Where legal ownership of assessee's brand was transferred to one of partners of assessee firm on account of business necessities, however, right to exploit brand name/logo/trademark etc. continued with assessee and hence assessee was beneficiary of AMP expenses/brand promotion, no TP adjustment could have been made in respect of AMP expenses on account of 'brand promotion'

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