also be seen that the royalty is paid to a
common source, that is, AIHPL.
4.5 The Company pays management fees to MSPL to liaise ... closely linked', if they emanate from a common source, being an
order or contract or an agreement or an arrangement, and the nature, characteristic
closely linked', if they emanate
from a common source, being an order or contract or an agreement or an
arrangement, and the nature, characteristic ... terms of such transactions
substantially flow from the said common source. The following extract from the
said Guidance Notes is worthy of notice
utilities which are
supplied from a common source which also services areas of the
plant other than R&D may be admissible, provided they
utilities which are supplied from a common source which also
services areas of the plant other than R&D may be admissible,
provided they
transfer pricing analysis.
Where two or more transactions emanate from common source being an order
or contract or an agreement or an arrangement, then such ... characteristic and terms of such
transaction substantially flow from the said common source."
24. It was submitted that the Assessee is a manufacturer
utilities which are supplied from a common source which also
services areas of the plant other than R&D may be admissible,
provided they
royalty are closely inter-linked, interdependent and flow from
a common source. He at the cost of repetition reiterated that once the net
profit margin
utilities which are supplied from
a common source which also services areas of the plant
other than R&D may be admissible, provided they
Chapter 8, defines
"INTANGIBLES AND NET WORTH AS UNDER";
Common Sources of funds for companies are its shareholders, through
the issue of shares ... Bang/2010 Page - 21
have made in the company and is commonly referred to as
'Shareholders funds' or 'Net Worth
royalty are closely inter-linked, interdependent
and flow from a common source. He at the cost of repetition
reiterated that once the net profit margin
