MOBITECH CREATIONS PRIVATE LIMITED vs DCIT, NEW DELHI
Whether the assessee qualifies as an 'Associated Enterprise' under section 92A of the Act in relation to One Plus Technology (Shenzhen) Co. Ltd. --- Held: No. Whether the royalty payment to One Plus Technology (Shenzhen) Co. Ltd. constitutes an 'International Transaction' under section 92B of the Act --- Held: No. Whether the disallowance of royalty expenditure u/s 37(1) is valid --- Held: No.
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