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

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