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ALP not to be computed if transaction is not with associated enterprise
Case Law Details
- Case Name
- Price Waterhouse & Anr. Vs Commissioner of Income Tax (Calcutta High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All High Courts, Calcutta High Court
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If an entity is not an “associated enterprise”, there cannot be any computation of income from “international transaction” having regard to ALP
Brief of the Case: In the case of Price Waterhouse & Anr. Vs CIT, Calcutta High Court through an interim order opined that if there was no relevant material in the hands of the Income Tax authorities with which it has come to an incontrovertible conclusion that the writ petitioner no.1 was an ‘associated enterprise’ of Pricewaterhouse Coopers Services BV, within the meaning of section 92A of the Income Tax Act, 1961, the questio...
