Case Law Details
Case Name : The Dy. Commissioner of Income Tax Vs. M/s. Indo American Jewellery Limited (ITAT Mumbai)
Appeal Number : ITA No. 5872/Mum/2009
Date of Judgement/Order : 22/02/2012
Related Assessment Year : 2005- 2006
Courts :
All ITAT ITAT Mumbai
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Even if we accept the contention of the ld. DR that the non-charging of interest from AEs in the transaction of sale could in itself be construed as an international transaction, then also going by the CUP method, no such adjustment can be made because th0ontrolled transactions is comparable with that of non-charging from the uncontrolled transactions, no transfer pricing adjustment can be made on this count. We, therefore, hold that no addition on account of such interest can be made.
INCOME TAX APPELLATE TRIBUNAL, MUMBAI
ITA No. 5872/Mum/2009 : Asst. Year: 2005- 2006
The Dy. Commissioner of Income Tax
Vs.
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