Dresser-Rand India (P.) Ltd. v. Addl. CIT
13 Taxmann.com 82High Court2011#2688 most cited
What is Dresser-Rand India (P.) Ltd. v. Addl. CIT authority for?
An Assessing Officer cannot disregard an assessee's decision to avail services from associated enterprises, even if the assessee has internal expertise, as the determination of necessity is the assessee's prerogative. The Transfer Pricing Officer's role is to determine the arm's length price, not the need for the service itself.
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judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2016 to 2025.
Also referred to as
Dresser-Rand India (P.) Ltd. v. Addl. CIT · section 92CA · intra group services · cost contribution charges · associated enterprise · arm's length price · benchmarking analysis · transactional net margin method · most appropriate method · taxpayer prerogative
