Ltd. v. ACIT(supra)CSR India(P) Ltd Vs ITO
31 Taxmann.com 265Income Tax Appellate Tribunal2013#10508 most cited
What is Ltd. v. ACIT(supra)CSR India(P) Ltd Vs ITO authority for?
Companies with related party transactions exceeding 15% of operating income or 10% of operating expenses are not comparable entities for transfer pricing purposes.
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judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2015 to 2021.
Also referred to as
CSR India Pvt Ltd v ITO · 31 taxmann.com 265 · transfer pricing · related party transactions · comparable companies · operating income · operating expenses · ITAT Bangalore