convertible
debentures are taken as FDI which is clear from RBI Circular
No. 74(RBI/2006-2007/435) (copy of which is placed at page ... issued by the Department of Industrial Policy and
promotion (DIPP), RBI guidelines and FEMA regulations,
the issuance of the CCD is part of FDI being
agreement' entered with JM UK was duly approved by RBI and Foreign
Investment Promotion Board (FIPB) and as per the terms of the
agreement ... years from the date of grant of approval from the RBI. Accordingly, the
royalty was payable for the period between financial year
agreement' entered with JM UK was duly approved by RBI and Foreign
Investment Promotion Board (FIPB) and as per the terms of the
agreement ... years from the date of grant of approval from the RBI.
Accordingly, the royalty was payable for the period between financial
year
submitted to the Foreign Investment
Promotion Board [FIPB], Reserve Bank of India [RBI] for their information
in accordance with the prevailing law. Assessee also contended
letters clearly state as under:
"The INDO-FRENCH centre for the promotion of advanced research will be exempt from payment of Income ... French bank in Paris for the purpose of promotion of advanced research. Copies of letters from RBI dated 04.07.1988 and 05.09.1988 are enclosed as Annexure
equity. Approval for
foreign investment promotion Board was obtained on 5 March 2007
and approval of SEBI and RBI were granted on 23rd March
rendering the services for promotion and sales of the products of the
assessee company. That apart from getting permission from RBI for
opening the liaison
proportion in which it incurs expenditure on R&D and Brand promotion.
16.10. Without prejudice, the assessing officer erred in considering the
consolidated financials ... assessing officer erred in failing to appreciate the
permissible limits of RBI for the payment of the brand royalty i.e. 5% on domestic
sales
subscription and advertisement
air time drive towards the same end of promotion of channels. As
regards to the objection of the TPO/AO that there ... pursuant to the change in the foreign exchange
regulations of the RBI vide Circular No. 76 which relaxed the condition
of export earnings by advertisers
export
sales is within the limits prescribed by the RBI in the earlier year
and was a bonafide transaction.
3.4 That the assessing officer ... relation to the advertisement, marketing and
sales promotion expenses (hereinafter referred to as 'the AMP
expenses') incurred by the appellant.
4.1 That
