No adjustments Arms Length Price (ALP) required when difference between ALP determined by assessee and by AO varies not more than 5 per cent

CASE LAWS DETAILS DECIDED BY: ITAT, DELHI BENCH `B’, NEW DELHI, IN THE CASE OF: Electrobug Technologies Ltd. Vs ACIT, Appeal No: ITA No. 1898/Del/2009, DECIDED ON: December 4, 2009 RELEVANT PARAGRAPH 2. The assessee company was incorporated on 30-1-2003 and this is the first return filed by the assessee company since its incorporation. The company is branch office of Electrobug Technologies Ltd., U.K. operating in India to support their activities. Main business of the assessee company is to retrieve and extract Data for clients of their Head Office against which it raises invoices to i...