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When information available in public domain is not sufficient to make the comparisons possible, then some approximations and reasonable assumptions are to be made
Case Law Details
- Case Name
- Skoda Auto India Pvt. Ltd. Vs ACIT (ITAT Pune)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
RELEVANT PARAGRAPH
19. One of the things which is clearly discernable from the facts of this case is that so far as the year before us is concerned, which was incidentally first full year of assessee’s operations, the import content of the raw materials was as high at 98.95%. This is materially different from the import content of the raw material in the cases of the com parables selected by the revenue authorities. The import content of raw material in these cases ranged from 26% to 56.83% [Hindustan Motors- 31%; Honda Siel -48.2%; Hyundai Motors – 25.29%; General Motors 56.83% and Ma...
