Case Law Details
In the case of CIT v Canon India Pvt. Ltd., Hon’ble High Court held that whenever a subsidiary company is getting subsidy from it’s holding company, then the amount of subsidy which has not been spent will not be considered as income of the Assessee.
Facts of the Case
The Assessee is a subsidiary company which started its operations in India in 1996. During the course of its business, the Assessee entered into various agreements/transactions with its Group Companies. These transactions pertained to purchase and resale of products such as photocopiers, printers, scanners and cameras in India. The Assessee filed its return of income for the AYs in question and disclosed the transactions with its Associated Enterprises. The AO made a reference under Section 92CA of the Act to the Transfer Pricing Officer for determination of Arm’s Length Price in respect of various transactions
entered into by the Assessee during the relevant AYs.
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