Transfer Pricing Provision- Mere geographical contiguity of two countries need not mean similarity in economic or market conditions

CASE LAWS DETAILS DECIDED BY: ITAT, MUMBAI BENCH `L’, MUMBAI, IN THE CASE OF: Intervet India Pvt. Ltd. Vs. ACIT, APPEAL NO: ITA No. 2845/Mum/2006, DECIDED ON : March 31, 2010 RELEVANT PARAGRAPH We heard both Parties. From the submissions made by the assessee the economic and market conditions of Thailand and Vietnam are totally different. The Ld. CIT (A) has held that both the countries are located in Far East Asia and have similar demo graphical constitution. Therefore in the circumstances, where the product in the transaction is similar and location of the concerned parties are somewh...