Transaction price to be viewed as arm’s length price as payments made with specific regulatory approval

Ambuja Cement Limited Vs ACIT (ITAT Mumbai) ITAT Mumbai held that payments under the BBCD arrangements were made with specific regulatory approval prescribed by the RBI hence that approval can also be viewed in support of the transaction price as an arm’s length price. Facts- During the course of proceedings before the Transfer Pricing Officer, to whom the ascertainment of Arm’s Length Price of the international transactions entered into by the assessee with its AEs was referred, it was noticed that the assessee made instalment payments for two ships under Bare Boat cum Charter Demise (BBC...