Margins derived on export of parts to AE are not comparable with margins derived from sales in domestic market

CIT V. Keihin Fie (P.) Ltd. (Bombay High Court)

Hon’ble Bombay High Court held that Margins derived on export of parts to AE can not compared with margins derived from sales made in domestic market.

Outcome: In favor of Assessee

Issue:

Whether on the facts and in the circumstance of the case and in law, the Tribunal was correct in law in holding that the two segments viz: manufacturing and trading are comparable to determine the Arms Length Price (ALP) of the trading goods exported to AE?

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