Adoption of arms length price as NIL is untenable

Sulzer Tech India Pvt. Ltd. Vs Addl./Jt./Dy./Asstt. Commissioner of Income Tax (ITAT Mumbai) Held that treating value of international transaction as NIL without searching for transaction between non-associated enterprises is unsustainable in law Facts- The assessee is mainly engaged in the business of providing design and engineering services and drawings relating to engineering and IT services. The assessee is a global technical resource centre to support Sulzer Group Companies. AO determined the arm’s length price of IT support services to be NIL. Ld. DRP rejected the objection filed by t...