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Case Law Details

Case Name : Marubeni India Pvt. Ltd. Vs ACIT (ITAT Delhi)
Related Assessment Year : 2002- 03
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Marubeni India Pvt. Ltd. Vs ACIT (I.T.A. No. 919/Del/2009)- ITAT Delhi

Delhi Tribunal Ruling –-Interest income is to be excluded from operating revenue for computing the net profit from operating activity unless such interest income has nexus with the international transaction. Under the captive service and cost plus model, if an expense has a direct link with the international transaction, the same should form part of total cost i.e. operating costs. The onus is on the taxpayer to maintain robust documentat

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