Foreign Associated Enterprises can be treated as tested parties for comparables: ITAT Kolkata

ACIT Vs ITC Infotech India Limited (ITAT Kolkata) ITAT Kolkata held that foreign Associated Enterprises are least complex entities and accordingly can be treated as tested parties for comparability analysis of international transaction. Facts- The present appeal is filed by the revenue mainly contesting that CIT(A) has erred in accepting the foreign Associated Enterprise as tested party for establishing arm’s length price. It is also contested that CIT(A) has erred in accepting the foreign AEs as tested party without appreciating that the accounts of AEs are based on the accounting policies...