Case Law Details
Case Name : PCIT Vs Freescale Semiconductor India Pvt Ltd (Delhi High Court)
Appeal Number : ITA 19/2019
Date of Judgement/Order : 28/10/2024
Related Assessment Year : 2013-14
Courts :
All High Courts Delhi High Court
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PCIT Vs Freescale Semiconductor India Pvt Ltd (Delhi High Court)
Delhi High Court held that functionally dissimilar entities cannot be included as a comparable entity for benchmarking the Arm’s Length Price (ALP) of the international transactions. Accordingly, appeal of the revenue dismissed.
Facts- The assesse
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