Transfer Pricing: No penalty for mere difference in level of capacity utilization

PCIT Vs. M/S Giesecks & Devrient (India) Pvt. Ltd. (Delhi High Court)

The appeal is filed by the revenue against the order passed by the Hon’ble ITAT Delhi (I-2 Bench) in ITA No. 3864/DEL/2015.

Background of the Case:

M/S Giesecks & Devrient (India) Pvt. Ltd (hereinafter referred as the “Respondent”) is a wholly owned subsidiary of Giesecke & Devrient Gmbh (hereinafter referred to as ‘G&D G

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