Transfer pricing study of assessee and ALP of international transactions determined on the basis of such study simply cannot be rejected without any cogent reasons

JUDGEMENT PER R.K.PANDA, AM, This appeal filed by the Revenue is directed against the order dated 12th August, 2008 of the CIT(A)-XIX, Mumbai relating to assessment year 2004-05. 2. Facts of the case, in brief, are that the assessee company M/s. Indo American Jewellery Pvt. Ltd., previously known as Suashish Jewellery Ltd., is a closely held Indian company incorporated on 16th July, 1999. It is engaged in the business of manufacturing and export of plain and studded jewellery of gold, platinum, silver and other precious/semi precious diamonds, synthetic stones in the form of rings, pendants, e...