Tagged “royalty”

3 articles on royalty.

TribunalIncome Tax Appellate Tribunal, Delhi

Bellsonica Auto Component India v. ACIT (2026): a transfer-pricing royalty adjustment must be capped at the rate the CBDT accepted under the assessee's APA

The ITAT Delhi held that where the CBDT has accepted a royalty and technical-fee rate of 1.9% of net sales under the assessee's Unilateral Advance Pricing Agreement, the Transfer Pricing Officer's higher adjustment is excessive and must be capped at the APA-accepted rate. A digest of the facts, the arm's-length question, and why a concluded APA carries persuasive weight.

Valkya Editorial·21 Jun 2026·7 min

TribunalNational Company Law Appellate Tribunal

Lyka Labs v. Modi Lifecare: invoices not mandatory for Section 9 IBC admission under a Technical Guidance Agreement

NCLAT Principal Bench (Bhushan CP, Mitra and Baroka) holds that where a Technical Guidance Agreement itself creates a minimum-royalty obligation, the absence of invoices does not defeat a Section 9 application; ₹63 lakh deposit ordered failing which CIRP admission follows.

Valkya Editorial·2 Jun 2026·9 min

Supreme CourtSupreme Court of India

Mineral Area Development Authority v. SAIL: royalty is not a tax

On 25 July 2024, a nine-judge bench held 8:1 that mining royalty is not a tax and that States may tax mineral rights and mineral-bearing land, overruling India Cement.

Valkya Editorial·1 Jun 2026·8 min