Case Law Details
Case Name : M/s Aithent Technologies Pvt Ltd., Vs Income Tax Officer (ITAT Delhi)
Related Assessment Year : 2002- 03
Courts :
All ITAT ITAT Delhi
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M/s Aithent Technologies Pvt Ltd. V/s. ITO (ITAT Delhi)- Indisputably, the aforesaid international transaction of interest free loan to the AE is an independent transaction ,requiring determination of ALP. The assessee in their transfer pricing study inferred that no external comparable uncontrolled price was available for bench marking this transaction and thus, it
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