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1. Sesa Goa Ltd. vs JCIT, 117 taxmann.com 96 (Bombay);

2. Voltas India Ltd. vs. ACIT, 117 taxmann.com 547 (Mum-Trib.);

3. Atlas Copco India Ltd. vs. ACIT, 112 taxamann.com 120 (Pune-Trib.); and

4. Symantec Software India P. Ltd. vs. DCIT,114 taxmann.com 455 (Pune-Trib.).

3.2. In respect of ground No.5 of the appeal, the ld. Counsel for the assessee submitted that the Transfer Pricing Officer (TPO) has erred in holding that distribution fee paid by the assessee to its Associated Enterprise (AE) is in the nature of royalty. The Tribunal in assessee's appeal for assessment year 2013-14 has already dealt with this issue and after placing reliance on the order of Tribunal in assessee's own case for assessment year 2011-12, held that distribution fee paid by the assessee is not in the nature of royalty.