Comparable controlled transaction not to be taken as comparable to benchmark international transaction

Vodafone Idea Ltd Vs ACIT (ITAT Delhi)

ITAT Delhi held that comparable controlled transaction cannot be taken as comparable to benchmark the international transaction. Accordingly, transfer pricing adjustment in respect of international transaction towards payment of royalty deleted.

Facts- The Assessee, Vodafone Idea Ltd, by filing the present appeal sought to set aside the impugned order dated 30.08.2019 passed by the Assessing Officer (AO) under section 143(3) r.w.s. 143C of the Income Tax Act, 1961 inconsonance with the order passed by the Dispute Resol

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