view, it would be at the most one of the
supporting tools to justify the rate of payment, but it cannot be only ... course act as one of the supportive
tools for carrying out bench marking of transaction of payment of royalty.
Thus, under these circumstances
transactions. It has set aside the matter for de novo bench marking of
the international transaction involving the AMP expenditure de hors ... assessment with the understanding that they have the BLT
tool to bench mark the international transaction of AMP expenditure. Even
Hon'ble ITAT accepted
cost actually incurred by the Assessee and that no profit element or mark-up on the
cost would be added to it. Article ... systems
development and computer. usage, communication services, engineering
services, product, process and tool design services, manufacturing services,
capital, planning and inventory management services, metallurgical Services
cost actually incurred by the Assessee and that no profit element or mark-up on the
cost would be added to it. Article ... systems
development and computer. usage, communication services, engineering
services, product, process and tool design services, manufacturing services,
capital, planning and inventory management services, metallurgical Services
erred in not considering and rejecting Kabra Winders Ltd. and
United Drilling Tools Ltd. as comparable companies.
2. The learned Lower Authorities erred ... Tools
Limited, as comparables while determining of the arm's
length price.
3. The learned Lower Authorities erred in computation of
operating cost mark
cost actually incurred by the Assessee and that no profit element or mark-up on the
cost would be added to it. Article ... systems
development and computer. usage, communication services, engineering
services, product, process and tool design services, manufacturing services,
capital, planning and inventory management services, metallurgical Services
cost actually incurred by the Assessee and that no profit element or mark-up on the
cost would be added to it. Article ... systems
development and computer. usage, communication services, engineering
services, product, process and tool design services, manufacturing services,
capital, planning and inventory management services, metallurgical Services
design, assistance for tool drawings, Jigs, Fixtures etc for monitoring of project in all respects, testing quality standard / certification / bench marking, new process arrangements
marks out of which 10 marks should
be given to quality of the formatting of final out-put and remaining
40 marks should be given ... mark each for every feature of formatting.
(6) There is no bar to candidates:
| (i) correcting the mistakes by use of editing tools while typing
rights need not answer the
description of "know-how, patents, trade marks, licences or franchises" but must be
of similar nature ... only the aforesaid six categories of assets, viz., know-how, patents, trade marks,
copyrights, licences or franchises. The nature of "business or commercial rights
