joint venture (JV) company (of the assessee and its foreign technical
collaborator, M/s. Piaggio Cspa) engaged in the manufacturing of two wheelers, claimed ... wheeler business, having set up a scooter project in
technical collaboration with M/s. Piaggio Cspa, Italy in 1982-83 for manufacturing one
lac scooters
appellant
company entered into an agreement with a British company. The technical collaborator
agreement provided for payment of Pound7,500 payable by 3 instalments ... agreement. The tribunal found that for the obligation to give technical assistance and
collaboration for putting up the factory, no payment was envisaged under
that, the group has
established around 13 joint ventures and 7 technical
collaborations. The assessee submitted that 99% of the investment
held by the assessee
increasing the share capital base
was necessary precondition for continuance of technical
collaboration arrangement by the assessee. The
following analysis of legal position
held that
certain royalty paid to Unilever Plc. under the Technical Collaboration
Agreement dated 12 August 1999 and the intra group services should
be benchmarked
Mondelez India Foods P. Ltd, Mumbai vs Dcit Rg 5(1)(2), Mumbai on 31
crucial bearing in
determining whether CAUSA has authorised the
assessee to use technical knowhow along with
trademark, hence, is admitted as additional evidence.
Even, without ... noted that the assessee entered into Technical
collaboration Agreement dated 28/06/2007 with CEPT to
avail the benefits of Technical Know-how, trade secrets
price of products manufactured and sold in India as
per the technical collaboration agreement. This internatio-
nal transaction involving payment of royalty
Skol Breweries Ltd, Mumbai vs Assessee on 29 July, 2011
IN THE INCOME TAX APPELLATE
company was tied up wit h
Acuity/Sparkle Group USA for technical collaboration and
also to make the assessee company as a 100% subsidiary
