Transfer pricing provisions not apply to operations carried through qualifying ships

Van Oord India Pvt Ltd Vs DCIT (ITAT Mumbai) Held that the transfer pricing provisions are not applicable to the assessee to the extent of operations carried out through operating qualifying ships where the income is taxed under Tonnage Tax Scheme. Facts- The assessee is a wholly owned subsidiary of Van Oord Dredging and Marine Contractors BV, a company registered in the Netherlands. The assessee over the years has become a main contractor directly entering into contracts with Government and port authorities in India. The assessee also owns certain equipment which it uses for undertaking speci...