Average price of Kingsman Publication report and NYBOT to be considered for computing ALP

ACIT Vs Cargil India Pvt. Ltd. (ITAT Delhi)

ITAT Delhi affirmed direction of CIT(A) to take average of prices reported in Kingsman Publication report and New York Board of Trade [NYBOT] price after converting FOB as per Comparable Uncontrolled Price [CUP] for purpose of computing ALP on issue of import sugar.

Facts- The assessee company is a company incorporated as per the provisions of Companies Act, 1956. The case of assessee was selected for scrutiny. AO made additions/ disallowances of discounting charges amounting to Rs.5,72,77,093/-; deemed dividend a

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