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Letter of Comfort didn’t constitute International Transaction: TP adjustment deleted
Case Law Details
- Case Name
- Shapoorji Pallonji and Company Private Limited Vs DCIT (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2012-2013
- Courts
- All ITAT, ITAT Mumbai
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Shapoorji Pallonji and Company Private Limited Vs DCIT (ITAT Mumbai)
ITAT Mumbai held that transfer pricing addition made in respect of Letter of Comfort rightly deleted since Letter of Comfort didn’t constitute an International Transaction. Accordingly, order passed by CIT(A) upheld to that extent.
Facts- The Assessee is a domestic company primarily engaged in the business of civil construction, real estate, trading of construction materials and construction related services. The case of the Assessee was selected for scrutiny. During the course of assessment proceeding,...





