Bangalore Tribunal remits benchmarking of brand royalty in light of BEPS Action Plan 8-101
The assessee, an Indian company, is a telecom software solutions provider which offers software services, development consultancy and wireless software products to companies in the communication space and had multiple subsidiaries in USA, China, Finland and other countries around the world.
The assessee had entered into international transactions with its Associated Enterprises (‘AEs’) amounting to INR 19,42,13,399 during AY 2013-14.