How many judgments cite Knorr-Bremse India (P) Ltd. v. ACIT?

63 judgments on BharatTax cite Knorr-Bremse India (P) Ltd. v. ACIT (380 ITR 307), spanning 2016 to 2025.

Which sections of the Income Tax Act does Knorr-Bremse India (P) Ltd. v. ACIT come up under?

It is most often cited in judgments turning on Section 144C(13), Section 92CA, Section 10B, Section 142(1), Section 143(2), Section 143(3).

Knorr-Bremse India (P) Ltd. v. ACIT

380 ITR 307High Court2016#1799 most cited

What is Knorr-Bremse India (P) Ltd. v. ACIT authority for?

When transactions are part of a package deal with a composite price or are interdependent such that an assessee must accept all of them together, they must be aggregated and treated as a single international transaction for transfer pricing purposes.

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2016 to 2025.

Also referred to as

Knorr-Bremse India (P) Ltd. v. ACIT · 380 ITR 307 · aggregation of international transactions · transfer pricing · package deal · composite price · interdependent transactions · single international transaction · Section 92CA · Section 144C · related party transaction

Sections most often in play

Section 144C(13)Section 92CA Section 10B Section 142(1)Section 143(2)Section 143(3)Section 144C(1)Section 234A

Read the full judgment

Issues it is cited on

use of equipment comparable uncontrolled price method intra group services far analysis transfer pricing order related party transaction cup method tested party right to receive mli most appropriate method comparable companies

Judgments citing Knorr-Bremse India (P) Ltd. v. ACIT

Sika India Pvt. Ltd., Kolkata vs. DCIT, Cir-11, Kolkata

In the result, appeal of the assessee is allowed in part and in appeal of the revenue is dismissed

ITA 393/KOL/2014[2009-2010]Status: DisposedITAT Kolkata10 Oct 2018AY 2009-2010

Bench: Sri J. Sudhakar Reddy & Sri S.S. Viswanethra Ravi]

Section 144CSection 144C(5)Section 92C

…of closely linked transactions can be aggregated, but, the transactions which are not closely related to each other would require determination in a segregated manner. 5.4. The Hon'ble Punjab & Haryana High Court in Knorr Bremse India P. Ltd. vs. ACIT (2016) 380 ITR 307 (P&H), has held that in case of a package deal where each item is not separately valued, but, all are given a composite price, this should be considered as one international transaction and processed accordingly for the transfer pricing purpose. It further held that where a number of transactions are priced differently, but, on the understanding…

Wrigley India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

The appeal of the assessee are allowed accordingly

ITA 656/DEL/2015[2010-11]Status: DisposedITAT Delhi25 Sept 2018AY 2010-11

Bench: Shri Amit Shukla & Shri Prashant Maharishiwrigley India Pvt. Ltd, Vs. Dcit, 206, Okhla Industrial Estate, Circle-27(2), Phase-Iii, New Delhi New Delhi Pan: Aaacw1789P (Appellant) (Respondent)

For Appellant: Shri C.S. Aggarwal, Sr. AdvFor Respondent: Shri Sanjai Kumar Yadav, Sr

Section 143Section 143(3)Section 144CSection 92BSection 92F

…al Commisssioner of Income-tax [2016] 381 ITR 227 (Delhi) vii. Denso India Ltd. vs. Commissioner of Income-tax [2016] 388 ITR 324 (Delhi) viii. Expenditure had been incurred on account of commercial expediency: Knorr-Bremse India (P.) Ltd. vs. Asst. CIT 2016] 380 ITR 307 (Punjab & “ Wrigley India Pvt. Ltd Vs DCIT, 11. He further referred to the various documents submitted in the paper book to support his claim, such as the annual accounts of the assessee and the methodology adopted by the assessee for determination of ALP of the international transactions contained therein. He further referred to the various subm…

Firmenich Aromatics (India) P. Ltd, Mumbai vs. DCIT 9(3)(1), Mumbai

In the result, assessee’s appeal is partly allowed

ITA 2590/MUM/2017[2012-13]Status: DisposedITAT Mumbai23 Jul 2018AY 2012-13

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri Dhanesh Bafnaa/wFor Respondent: Shri Jayant Kumar

Section 143(3)Section 144C(13)

…a correct approach. He submitted, unless the transaction with the A.E. is a composite transaction, it cannot be aggregated. In this context, he relied upon the decision of the Hon'ble Punjab & Haryana High Court in Knorr Bremse India Pvt. Ltd. v/s CIT, [2016] 380 ITR 307 (P&H). The learned Departmental Representative submitted, the assessee has determined the arm's length price on the basis of a circular issued by the Ministry of Commerce, which is also not in accordance with the statutory provisions. He submitted, if the ad–hoc adjustment made by the Transfer Pricing Officer is held to be not in accordance with…

Sas Institute (India) P. Ltd, Mumbai vs. Asst CIT 1(3)(1), Mumbai

In the result, both the appeals filed by the assessee are treated as allowed

ITA 506/MUM/2016[2011-12]Status: DisposedITAT Mumbai22 May 2018AY 2011-12

Bench: Shri B.R. Baskaran (Am) & Shri Ramlal Negi (Jm)

…oyalty. Even though the assessee was providing different kind of services, it is necessary to adopt integrated approach for determining arm’s length price as held by Hon'ble Punjab & Haryana High Court in the case of Knorr-Bremse India (P) Ltd vs. ACIT (2016) 380 ITR 307. Accordingly, the learned DR submitted that the issue may be restored to the file of the Assessing Officer/TPO for examining it afresh, as held by Coordinate Bench of Tribunal in assessee’s own case for A.Y. 2008-09 & 2010-11. 6. We have heard the rival contentions on this issue. We noticed that the Coordinate Bench of the Tribunal has restored a…

M/S Ther Structural Waterproofing Company Private Limited, Mumbai vs. ACIT, Circle-10(2), Kol, Kolkata

In the result, the appeal filed by the assessee, is allowed

ITA 112/KOL/2017[2012-13]Status: DisposedITAT Kolkata04 May 2018AY 2012-13

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.112/Kol/2017 ("नधा"रणवष" / Assessment Year: 2012-13) Chryso India Private Vs. A.C.I.T, Circle-10(2), Kolkata Limited (Formerly Known As ‘The Structural Waterproofing Company Private Limited’) Plot No.D-30/7, Ttc Industrial Area, Aayakar Bhavan, P-7, Chowringhee M.I.D.C, Turbhe, Navi Square, Kolkata – 700 069. Mumbai-400 705 (Maharashtra) "थायीलेखासं./जीआइआरसं./Pan/Gir No. :Aabct 0878 M (Appellant) .. (Respondent)

For Appellant: Shri Akhilesh Gupta, ARFor Respondent: Shri G. Mallikarjuna, CIT, DR

Section 143(3)Section 144CSection 271(1)(c)Section 92C

…ssessee for such services, the economic and commercial benefits derived by the Assessee of intragroup services. 16.2. We also find that in the recent decision of the Hon’ble Delhi High Court in the case of Knorr-Bremse India (P) Ltd vs ACIT reported in (2016) 380 ITR 307 (Del) wherein the relevant head notes is reproduced hereinbelow :- Section 92C of the Income-tax Act, 1961 - Transfer pricing - Computation of arm’s length price (Comparables and adjustments/Adjustments - General) - Assessment year 2007-08 - Whether answer to issue whether a transaction is at an arm's length price or not is not dependent on wheth…

M/S. Philips India Limited (Formerly Philips Electronics India Litd.), Kolkata vs. ACIT, Circle - 12(2), Kolkata

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 2489/KOL/2017[2013-14]Status: DisposedITAT Kolkata04 Apr 2018AY 2013-14

Bench: Hon’Ble Shri A.T.Varkey, Jm & Hon’Ble Shri M.Balaganesh, Am ] I.T.A No. 2489/Kol/2017 Assessment Year : 2013-14 M/S Philips India Ltd. -Vs- Acit, Circle-12(2), Kolkata (Formerly Philips Electronics India Ltd.) [Pan: Aabcp 9487 A] (Appellant) (Respondent)

For Appellant: Shri Arvind Sonde, AdvocateFor Respondent: Shri G. Mallikarjuna, CIT DR

Section 143(3)Section 92CSection 92D(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH : KOLKATA [Before Hon’ble Shri A.T.Varkey, JM & Hon’ble Shri M.Balaganesh, AM ] I.T.A No. 2489/Kol/2017 Assessment Year : 2013-14 M/s Philips India Ltd. -vs- ACIT, Circle-12(2), Kolkata (formerly Philips Electronics India Ltd.) [PAN: AABCP 9487 A] (Appellant) (Respondent) For the Appellant : Shri Arvind Sonde, Advocate For the Revenue : Shri G. Mallikarjuna, CIT DR Date of Hearing : 19.03.2018 Date of Pronouncement : 04.04.2018 ORDER Per M.Balaganesh, AM 1. This appeal filed by the assessee against the assessment order of the ACIT Circle-12(2), Kolkata,…

M/S Phillips India Limited, Kolkata vs. ACIT, Cir-12(2), Kolkata

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 612/KOL/2017[2012-13]Status: DisposedITAT Kolkata07 Feb 2018AY 2012-13

Bench: Hon’Ble Shri N.V.Vasudevan, Jm & Hon’Ble Shri M.Balaganesh, Am ] I.T.A No. 612/Kol/2017 Assessment Year : 2012-13 M/S Philips India Ltd. -Vs- Acit, Circle-12(2), Kolkata (Formerly Philips Electronics India Ltd.) [Pan: Aabcp 9487 A] (Appellant) (Respondent)

For Appellant: Shri Arvind Sonde, AdvocateFor Respondent: Shri G. Mallikarjuna, CIT DR

Section 143(3)Section 92CSection 92D(1)

…ssessee for such services, the economic and commercial benefits derived by the Assessee of intragroup services. 4.8. We also find that in the recent decision of the Hon’ble Delhi High Court in the case of Knorr-Bremse India (P) Ltd vs ACIT reported in (2016) 380 ITR 307 (Del) wherein the relevant head notes is reproduced herein below :- 34 Philips India Ltd.. A.Yr.2012-13 Section 92C of the Income-tax Act, 1961 - Transfer pricing - Computation of arm’s length price (Comparables and adjustments/Adjustments - General) - Assessment year 2007-08 - Whether answer to issue whether a transaction is at an arm's length…

DCIT, Bangalore vs. M/S Adcock Ingram Limited, Bangalore

In the result, both the appeals of the revenue are allowed for statistical purposes

ITA 1039/BANG/2015[2009-10]Status: DisposedITAT Bangalore31 Jan 2018AY 2009-10

Bench: Shri. Jason P. Boaz

For Appellant: Shri. Vishnu Bagri, CAFor Respondent: Shri. Harinder Kumar, CIT - DR

Section 92B

…nch decision in the matter of Gulbrandsen Chemicals (P.) Ltd. v. Deputy Commissioner of Income-tax* [2017] 79 taxmann.com 105 (Ahmedabad - Trib.) had held as under 8 …………………………………….We find that, in the case of Knorr-Bremse India (P.) Ltd. v. Asstt. CIT [2016] 380 ITR 307/236 Taxman 318/[2015] 63 taxmann.com 186 (Punj. & Har.), Hon'ble Punjab & Haryana High Court has observed that "The doubt, if any, in this regard is set at rest by rule 10A(d), which provides that for the purpose of rule 10A and rules 10 B to 10E, 'transaction' includes a number of closely related transactions" and that "Thus, the closely linked…

DCIT, Cir-12(2), Kolkata vs. M/S Philips India Ltd., Kolkata

ITA 863/KOL/2016[2011-2012]Status: DisposedITAT Kolkata15 Dec 2017AY 2011-2012

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmed

Section 143(3)Section 144CSection 144C(5)Section 92C

…Assessee for such services, the economic and commercial benefits derived by the Assessee of intragroup services. 4.8. We also find that in the recent decision of the Hon’ble Delhi High Court in the case of Knorr-Bremse India (P) Ltd vs ACIT reported in (2016) 380 ITR 307 (Del) wherein the relevant head notes is reproduced herein below :- Section 92C of the Income-tax Act, 1961 - Transfer pricing - Computation of arm’s length price (Comparables and adjustments/Adjustments - General) - Assessment year 2007-08 - Whether answer to issue whether a transaction is at an arm's length price or not is not dependent on whet…

M/S Philips India Ltd., Kolkata vs. DCIT, Cir-12(2), Kolkata

ITA 539/KOL/2016[2011-2012]Status: DisposedITAT Kolkata15 Dec 2017AY 2011-2012

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmed

Section 143(3)Section 144CSection 144C(5)Section 92C

M/S. Volvo India Pvt. Ltd., Bangalore vs. DCIT, Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 1353/BANG/2010[2006-07]Status: DisposedITAT Bangalore11 Dec 2017AY 2006-07

Bench: Shri Inturi Rama Rao & Shri Lalit Kumarm/S.Volvo India Private Limited, Yalachahally Village, Tavarakere Post, Hoskote, Bangalore – 562 122. Pan: Aaacv 6747N … Appellant Vs. The Deputy Commissioner Of Income Tax, Ltu, … Respondent

For Appellant: Shri Neeraj Jain, CAFor Respondent: Ms. Neera Malhotra, CIT(DR)

Section 10ASection 143(3)Section 234CSection 234DSection 92C

…e, he further contended that the cost incurred by the AE is not a relevant criterion for determination of ALP and reliance in this regard was also placed on the Hon’ble Punjab & Haryana High Court decision in the case of Knorr- Bremse India (P.) Ltd. v. ACIT, 380 ITR 307 (P&H). Finally, he contended that merely because no management fee was charged by the AE in the earlier years cannot be a bar to charge fees in the subsequent years. Reliance in this regard was placed on judgment of the Hon’ble Supreme Court in the case of Shahzada Nand and Sons v. CIT (1977) CTR (SC) 246 and CIT v. Laxmi Cement Distributors (P)…

M/S Bright Point India Pvt Ltd., New Delhi vs. ACIT, New Delhi

In the result, the appeal filed by the assessee is allowed for statistical

ITA 123/DEL/2017[2012-13]Status: DisposedITAT Delhi04 Dec 2017AY 2012-13

Bench: Shri R. K. Panda & Shri Kuldip Singhassessment Year : 2012-13 Bright Point India Pvt. Ltd., Acit, Central Circle- 20, G-9, Block B-1, New Delhi. Mohan Co-Operative Industrial Vs. Estate, Mathura Road, New Delhi.

For Appellant: Shri Tarun Gulati, AdvFor Respondent: Shri H. K. Choudhary, CIT-DR

Section 143(3)Section 144CSection 253(1)Section 92C

…es. He submitted that the services are not duplicative in nature and the Assessing Officer has incorrectly gone on cost benefit. Relying on the following decisions, he submitted that benefit from a transaction need not be proved :- a. Knorr Bremse vs. ACIT, 380 ITR 307. b. E.I. DuPont India (P.) Ltd. vs. DCIT, (2016) 72 taxmann.com 215. 10 c. Sony Ericson Mobile Communications India (P.) Ltd. vs. CIT, 374 ITR 118. d. CIT vs. Cushman and Wakefield India (P.) Ltd., 367 ITR 730. e. Dresser Rand India (P) Ltd. vs. Addl.CIT, (2011) 13 taxmann.com 82. 13. Referring to the decision of the Hon’ble Punjab & Haryana High…

Gruner India Pvt. Ltd., New Delhi vs. ACIT, Circle- 10(2), New Delhi

In the result, appeal of the assessee is allowed partly for statistical purposes

ITA 6801/DEL/2017[2013-14]Status: DisposedITAT Delhi30 Nov 2017AY 2013-14

Bench: Sh. Amit Shukla & Sh. O.P. Kantassessment Year: 2013-14 Vs. Acit, Circle -10(2), New Delhi M/S. Gruner India Pvt. Ltd., 15, Dsidc, Okhla Industrial Area, Phase-Ii, Scheme -1, New Delhi Pan : Aadcg2938H (Appellant) (Respondent) & S.A. No. 660/Del/2017 [In Ita No. 6801/Del/2017] Assessment Year: 2013-14 Vs. Acit, Circle -10(2), New Delhi M/S. Gruner India Pvt. Ltd., 15, Dsidc, Okhla Industrial Area, Phase-Ii, Scheme -1, New Delhi Pan : Aadcg2938H (Appellant) (Respondent) Assessee By S/Sh. H.P. Agrawal & Pancham Sethi, Ca Department By Sh. Sanjay Goyal, Cit(Dr) Date Of Hearing 22.11.2017 Date Of Pronouncement 30.11.2017 Order Per O.P. Kant, A.M.:

Section 143(2)Section 234BSection 92C

ITO, Bangalore vs. M/S Safran Engineering Services India Private Limited, Bangalore

In the result, the appeal filed by the revenue is partly allowed

ITA 451/BANG/2015[2010-11]Status: DisposedITAT Bangalore20 Nov 2017AY 2010-11

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Raoit(Tp)A No.451/Bang/2015 (Assessment Year: 2010-11)

For Appellant: Ms.Neera Malhaotra, CIT(DR)For Respondent: Shri K.R.Vasudevan, Advocate

Section 10ASection 143(3)Section 92C

…laced on the decision of Delhi High Court in the case of Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT [2015] 374 ITR 118/231 Taxman 113/55 taxmann.com 240 and Punjab Haryana High Court in the case Knorr Bremse India (P) Ltd. v. Asstt. CIT [2016] 380 ITR 307/236 Taxman 318/[2015] 63 taxmann.com 186. It is not the case of the appellant that these transactions are closely linked with the other transactions and therefore the submission that these transactions should be bundled with other transactions cannot be accepted.” 11. In the present case, the assessee-company had not filed any evidence before lo…

Bmw India Private Ltd., Gurgaon vs. DCIT, Gurgaon

In the result, the appeal is partly allowed for statistical purposes

ITA 1406/DEL/2015[2010-11]Status: DisposedITAT Delhi10 Nov 2017AY 2010-11

Bench: Shri R.S. Syal & Shri K. Narasimha Charyassessment Year: 2010-11 Bmw India Private Ltd. Vs. Dcit 7Th Floor, Tower-B, Building Circle-1(1) No. 8, Dlf Cyber City, Phase Gurgaon Ii, Gurgaon Pan:Aabcb7140C (Applicant) (Respondent) Assessee By : Sh. Percy Pardiwala, Sr. Adv Department By : Sh. H.K. Choudhary, Cit-Dr Date Of Hearing : 08.11.2017 Date Of Pronouncement : 10.11.2017 Order Per R.S. Syal, Vp: This Appeal By The Assessee Emanates From The Final Assessment Order Dated 24.02.2015 Passed By The Assessing Officer (Ao) Under Section 143(3) Read With Section 144 C Of The Income-Tax Act, 1961

For Appellant: Sh. Percy Pardiwala, Sr. AdvFor Respondent: Sh. H.K. Choudhary, CIT-DR

Section 143(3)Section 144Section 92B(1)Section 92F

…e etc. on a consolidated basis under the TNMM. We do not approve the contention advanced on behalf of the assessee for such aggregation. Our view is fortified by the judgment of the Hon’ble jurisdictional High Court in Knorr Bremse India Pvt Ltd vs. ACIT 2016 380 ITR 307 (P&H). In that case, the Hon’ble High Court has identified three situations in which more than one transaction can be taken as one composite international transaction to be processed jointly, viz., in case of a package deal where each item is not separately valued but all are given a composite price; or where a number of transaction are priced d…

A.W. Faber Castell (India) P.Ltd, Mumbai vs. DCIT 9(1)(1), Mumbai

Appeal of the assessee is partly allowed

ITA 1037/MUM/2017[2012-13]Status: DisposedITAT Mumbai12 Apr 2017AY 2012-13

Bench: Shri C.N. Prasad & Shri Ashwani Taneja

For Appellant: Mr. M.P. LohiaFor Respondent: Mrs. Malathi Sridharan CIT(DR)

Section 144CSection 36(1)

…aken at arm’s length. Royalty is a separate international transaction, for this purpose, reliance can be placed on the decision of Punjab & Haryana High Court in the case of Knorr-Bremse India (P.) Ltd. v. ACIT (2015) 63 taxmann. Com 186/(2016) 236 Taxman 318/380 ITR 307. The RBI approval/FIPB approval is not determinative of ALP and cannot be considered to be a valid CUP. Automatic route under which FIPB approvals or RBI approvals are granted have been devised for the “ease of doing business”. These approvals emanate from other legislation or policy and are not in relation to determination of Arm’s Length Price.…

Espn Software India (P) Ltd., Gurgaon vs. DCIT (Ltu), New Delhi

In the result, the appeal of the department is dismissed and that of the assessee is allowed

ITA 3457/DEL/2013[2006-07]Status: DisposedITAT Delhi08 Feb 2017AY 2006-07

Bench: Sh. N. K. Saini, Am & Smt. Beena Pillai, Jm Ita No. 2059/Del/2012 : Asstt. Year : 2005-06 Asstt. Commissioner Of Income Vs M/S Espn Software India Ltd., 7Th Floor, Tower-C, Infinity Tax (Ltu), New Delhi-110017 Tower, Dlf, Phase-Ii, Gurgaon, Haryana (Appellant) (Respondent) Pan No. Aaace2334C

For Appellant: Sh. Kanchan Kaushal, CAFor Respondent: Sh. S. K. Jain, Sr. DR

Section 143(3)Section 92Section 92C

…ld be considered as one international transaction and 24 ESPN Software India Ltd. needs to be aggregated. The reliance was placed on the following case laws: " N.G.C Network ((India) P. Ltd. (2014) 50 Taxmann.com 240 (Bom) " Knorr Bremse India P. Ltd. (2016) 380 ITR 307 (P&H) 19. The ld. Counsel for the assessee submitted that the ld. CIT(A) was fully justified in accepting the stand of the assessee for aggregation of activities. As regards to the exclusion of M/s Sun TV Network India Ltd. and M/s Empire Industries ltd. which were selected by the TPO as comparable, it was stated that M/s Sun TV Network India Ltd…

ACIT (Ltu), New Delhi vs. M/S. Espn Software India Ltd., Gurgaon

In the result, the appeal of the department is dismissed and that of the assessee is allowed

ITA 2059/DEL/2012[2005-06]Status: DisposedITAT Delhi08 Feb 2017AY 2005-06

For Appellant: Sh. Kanchan Kaushal, CAFor Respondent: Sh. S. K. Jain, Sr. DR

Section 143(3)Section 92Section 92C

Pr. Commissioner of Income Tax-6 vs. Mitsui Prime Advanced Composites India Pvt. Ltd

ITA/913/2016HC Delhi17 Jan 2017

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE NAJMI WAZIRI

Section 271(1)(C)Section 92C

…ailed of under the three international transactions which were improperly dealt with by the TPO and consequently the AO. The Tribunal thereafter took note of the decisions of the Punjab and Haryana High Court in Knorr-Bremse India P. Ltd. vs. ACIT (2016) 380 ITR 307 (P&H) and then observed as follows: - “The only question is whether the transaction was entered into bona fide or not or whether it was sham and only for the purpose of diverting the profits. Reverting to the facts of the extant case, we have found out above that the three international transactions entered in to by the assessee with its AE…

Volvo India Pvt. Ltd vs. DCIT

In the result, the appeal filed by the assessee is dismissed

ITA 384/BANG/2013[2005-06]Status: DisposedITAT Bangalore16 Dec 2016AY 2005-06

Bench: Smt Asha Vijayaraghavan & Shri Inturi Rama Rao

For Appellant: Shri. P. J. Pardiwala, Sr. CounselFor Respondent: Shri. G. R. Reddy, CIT-DR-I

Section 143(3)Section 92C

…er and reliance in this regard can be placed on the decision of Delhi High Court in the case of Sony Ericsson Mobile Communications India Pvt. Ltd., Vs. CIT 374 ITR 118 and Punjab Haryana High Court in the case Knorr Bremse India (P) Ltd., Vs. Asst. CIT 2016 (380 ITR 307). It is not the case of the appellant that these transactions are closely linked with the other transactions and therefore the submission that these transactions should be bundled with other transactions cannot be accepted. 14. In the result, the appeal filed by the assessee is dismissed. Pronounced in the open court on this 16th day of Decembe…