Indian Income-Tax Appellate Tribunal Permits Reduction of US Company's Royalty Income Based on APA Signed by Indian AE

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The Indian Income-tax Appellate Tribunal (ITAT) accepts the assessee [Gemological Institute of America Inc]'s contention that the royalty amount refunded to its Indian AE [GIA India Laboratory Pvt Ltd or GIA-India] on the basis of an advance pricing agreement (APA) signed by GIA India, cannot be treated as income in the hands of GIA US.

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