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ThynkTax /Tax Reference /Case Laws /Maruti Suzuki - Royalty

Maruti Suzuki - Royalty

High Court·2020·ITR
Facts

Royalty paid by Maruti Suzuki India to Suzuki Japan for technology licensing. TPO held the rate excessive.

Issue

ALP determination using TNMM vs CUP for royalty payments.

Held

TNMM applied at entity level is appropriate when separate CUP data is not available.

Ratio

Selection of the most appropriate method is fact-specific; reliable CUP is preferred but not mandatory.

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