Letter of Comfort didn’t constitute International Transaction: TP adjustment deleted

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, the Assessing Of...