Start free trial
ThynkTax /Tax Reference /Case Laws /Maruti Suzuki - Royalty TPO

Maruti Suzuki - Royalty TPO

High Court·2017·ITR
Facts

Royalty payment to Suzuki Japan; TPO determined ALP at nil.

Issue

Validity of nil-ALP determination.

Held

TPO cannot reduce ALP to nil based on conceptual disagreement - must use one of the prescribed methods (CUP, RPM, CPM, PSM, TNMM, Other).

Ratio

ALP determination must follow statutory method; cannot be arbitrary.

Related judgments on the same sections

Supreme Court of India · 2019
Maruti Suzuki - AMP

Facts: Maruti Suzuki incurred substantial advertising, marketing and promotion (AMP) expenses for its products. TPO held this was an interna…

High Court · 2014
Bharti Airtel - Corporate guarantee

Facts: Bharti Airtel issued corporate guarantees for foreign subsidiaries. Issue: Is a corporate guarantee an "international transaction" re…

High Court · 2020
Maruti Suzuki - Royalty

Facts: Royalty paid by Maruti Suzuki India to Suzuki Japan for technology licensing. TPO held the rate excessive. Issue: ALP determination u…

High Court · 2017
Sony India - AMP first principles

Facts: Sony India marketing spend on parent's brand. Issue: AMP as international transaction. Held: AMP is not deemed international transact…

Income Tax Appellate Tribunal · 2021
PepsiCo - brand-building

Facts: Marketing spend by PepsiCo India for brand-building. TPO sought to add AMP adjustment. Issue: Bright-line test for AMP. Held: Bright-…

Use via API

Free, public REST. Fetch this judgment programmatically.

API docs 
curl https://api.thynktax.com/v1/tax-law/case-laws?q=Maruti%20Suzuki%20-%20Royalty%20TPO