Transfer pricing – Current year data can be used for comparability of international & uncontrolled transactions

IN THE ITAT MUMBAI BENCH ‘B’ Lionbridge Technologies (P.) Ltd. V/s. Deputy Commissioner of Income-tax IT Appeal No. 9032 (Mum.) of 2010 [Assessment Year 2006-07] JUNE 20, 2012 ORDER R.S. Syal, Accountant Member – This appeal by the assessee is directed against the order passed by the DCIT u/s 143(3) read with section 144C(13) of the Income-tax Act, 1961 (hereinafter called the ‘Act’) on 07.10.2010 in relation to the assessment year 2006-07. 2. The major issue in this appeal is against the confirmation of addition of Rs. 8,86,68,683 on account of t...