Transfer Pricing – ACIT vs. M/s. NGC Network (India) Pvt. Ltd.

It is most appropriate to compare the intra- group transactions for a particular year against independent com parables having data for the same year, if available, where such com parables have already been accepted by the Department for a subsequent year The Mumbai Bench ‘L’ of the Income Tax Appellate Tribunal (the “Tribunal”), on 23 February 2011, pronounced its ruling in the case ACIT Vs. M/s. NGC Network (India) Pvt. Ltd., Mumbai, ITA No. 5307/M/2008. The Taxpayer’s position under appeal filed by the Department with the Tribunal related to the use of independent comparables under...