TP: Temporary price differentials occurring due to fluctuation in treatment charges should be ignored

Brief about the case

In the case of Hindalco Industries Ltd. -Vs- The Addl. Commissioner of Income tax, there were several grounds on which the appeal was made, both by the revenue as well as the assessee. The major ground being of transfer pricing has been discussed here under. Other grounds have been discussed in the facts mentioned herein.

The Assessee-company purchased cooper concentrates from its AE as well as non-AEs – Assessing Officer noticed that purchase pric

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