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“international transaction”

Transfer PricingSection 92BSection 92B3,408 judgments

The decision most relied on for international transaction is Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT (374 ITR 118), cited in 499 judgments on BharatTax.

Leading authorities on international transaction

Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT
374 ITR 118 · 2015 · High Court
499
citing judgments

The existence of an international transaction for Advertising and Marketing Promotion (AMP) expenditure requires the revenue to discharge the burden of proof. An explanation inserted under Section 92B does not automatically make AMP expenditure an international transaction.

CIT v. EKL Appliances Ltd.
345 ITR 241 · 2012 · High Court
422
citing judgments

Transfer pricing adjustments for outstanding receivables are permissible only if the Tax Officer establishes, through analysis over a period, a pattern indicating an international transaction intended to benefit an associated enterprise. The Tax Officer cannot question purely business decisions like royalty payments or exceed jurisdiction by applying cost-benefit analysis to determine the arm's length price of services.

India Vs. Azadi Bachao Andolan 263 ITR 706 (SC); and Vodafone International Holdings B.V v. Union of India
341 ITR 1 · 2012 · Supreme Court
295
citing judgments

Legitimate tax planning is permissible, allowing taxpayers to arrange their affairs to minimize tax liabilities while respecting the "look at test" for transaction genuineness and the separate entity principle in corporate taxation. The source of funds for treaty-beneficial structures does not automatically invalidate the transaction.

Maruti Suzuki India Ltd. v. CIT
381 ITR 117 · 2016 · High Court
220
citing judgments

The Bright Line Test (BLT) is not a recognized method under the Income-tax Act and Rules for benchmarking advertising, marketing, and promotion (AMP) expenses or for determining the existence of an international transaction or its Arm's Length Price. The Revenue must first establish the existence and price of an international transaction before seeking an ALP adjustment.

Vodafone India Services (P.) Ltd. v. Union of India
368 ITR 1 · 2014 · High Court
172
citing judgments

The issue of shares and share premium is a capital account transaction, not an income-generating event, therefore Chapter X (Transfer Pricing) provisions are not attracted to deem notional or hypothetical income from such transactions.

Sir Kikabhai Premchand v. CIT
24 ITR 506 · 1953 · Supreme Court
156
citing judgments

One cannot make a taxable profit or loss from transactions with oneself, as profit only arises from dealings with external third parties, even when transferring assets between different accounts or divisions of the same entity.

PCIT v. Redington (India) Ltd.
430 ITR 298 · 2021 · High Court
132
citing judgments

A corporate guarantee issued to Associated Enterprises (AEs) is an international transaction under Section 92B, requiring adjustments for guarantee commission due to inherent risk. The reasonable arm's length rate for benchmarking such corporate guarantees can be determined using internal or external comparable uncontrolled prices.

Bausch & Lomb Eye Care (India) Pvt. Ltd. v. Additional CIT
381 ITR 227 · 2016 · High Court
127
citing judgments

The existence of an international transaction must be established before its arm's length price can be determined. An alleged 'excessive' AMP expenditure cannot unilaterally expand the scope of an international transaction if its existence is contested.

Judgments citing international transaction

DCIT, Bangalore vs. M/S Robert Bosch Engineering & Business Solutions Private Limited, Bangalore

In the result, the appeal filed by assessee stands allowed as indicated above and the appeal filed by revenue stands dismissed

ITA 445/BANG/2016[2011-12]Status: DisposedITAT Bangalore02 Feb 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 608/Bang/2016 Assessment Year : 2011-12 M/S. Robert Bosch The Deputy Engineering & Business Commissioner Of Solutions Pvt. Ltd., Income Tax, #123, Industrial Layout, Large Tax Payers Unit, Hosur Road, Koramangala, Circle 1, Bangalore – 560095. Vs. Bangalore. Pan: Aaacr7108R Appellant Respondent & It(Tp)A No. 445/Bang/2016 Assessment Year : 2011-12 (By Revenue) : Shri Percy Padiwala, Sr. Assessee By Advocate : Shri Sumer Singh Meena, Cit Revenue By Dr (Osd) Date Of Hearing : 20-12-2021 Date Of Pronouncement : 02-02-2022 Order Per Beena Pillaipresent Cross Appeals Are Filed By Assessee As Well As Revenue Against The Final Assessment Order Dated 28.01.2016 By The Ld.Dcit, Ltu, Circle -1, Bangalore U/S. 143(3) R.W.S. 144C Of The Act For Assessment Year 2011-12. In Revenue’S Appeal, The Following Grounds Are Raised. “1. The Directions Of Drp Is Opposed To Law & Facts Of The Case.

Section 10ASection 143(3)Section 144CSection 14ASection 80J

Appeal: 1. The Appellant is engaged in the business of Software Development and IT enabled services. During the year, the Appellant had entered into International Transactions and Page 5 of 33 IT(TP)A Nos. 445 & 608/Bang/2016 therefore as required under Chapter X of the Income ... notice u/s. 143(2) was issued to the assessee on 06.08.2012 and duly served. Notice u/s 142(1) were issued and duly served. As international transaction exceeded Rs.15 crores the case was referred to the Ld.TPO to determine the Arm’s length price vide this office letter dated

M/S. Acusis Software India Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-1(1)(2), Bengaluru

ITA 2702/BANG/2017[2013-14]Status: DisposedITAT Bangalore01 Feb 2022AY 2013-14

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 2702/Bang/2017 Assessment Year : 2013-14 M/S. Acusis Software India The Deputy Pvt. Ltd., Commissioner Of No. 17/2, Dollars Chamber, Income Tax, Lalbagh Road, Circle – 1(1)(2), Bangalore – 560 027. Bangalore. Vs. Pan: Aadca2415P Appellant Respondent Assessee By : Shri Chavali Narayan, Ca : Shri Sumer Singh Meena, Cit Revenue By (Dr) Date Of Hearing : 01-02-2022 Date Of Pronouncement : 01-02-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Final Assessment Order 12.10.2017 Passed By The Ld.Dcit, Circle-1(1)(2), Bangalore Relating To Assessment Year 2013-14 On Following Revised & Modified Grounds Of Appeal: “Based On The Facts & Circumstances Of The Case & In Law. Acusis Software India Private Limited (Hereinafter Referred To As 'Appellant). Respectfully Craves Leave To Prefer An Appeal Against The Appeal Order Passed By The Learned Assessing Officer [Hereinafter Referred To As The 'Learned Ao'] Under Section 143(3) Read With Section 144C Of The Income-Tax Act. 1961 ('The Act') On The Following Grounds:

For Appellant: Shri Chavali Narayan, CA
Section 133(6)Section 143(3)Section 144CSection 271(1)(c)

Associated Enterprise ("AE") for which it is remunerated on a cost plus basis. During the year under consideration, assessee entered into following international transaction with its AE. Nature of International Amount in INR Transaction Provision of medical transcription 238,517,198 services The assessee undertook a Transfer Pricing (“TP”) study ... servicing the residential mortgage industry and also providing full spectrum of mortgage technology services for its group companies and adopted TNMM method for international transactions. The learned AR contention that Infosys BPO Ltd., is providing high end integrated services and also diversified services like business platforms, customer service outsourcing, finance

Deutsche Cib Centre P.Ltd, Mumbai vs. Asst CIT 12(2)(1), Mumbai

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

ITA 2179/MUM/2015[2010-11]Status: DisposedITAT Mumbai31 Jan 2022AY 2010-11
Section 143(3)Section 144C(1)Section 144C(5)Section 37

service provider. The ld. TPO 11 M/s. Deutsche CIB Centre Private Limited categorised assessee as a Knowledge Process Outsourcing (KPO) service provider. The international transactions carried out by the assessee with its AEs as reported in Form 3CEB are as under:- Sl. Nature of transaction FY 2009-10 F.Y.2008-09 Method ... requires domain knowledge, analytical skills and decision making capabilities. Accordingly, the ld. TPO identified the comparable companies and sought to benchmark the international transactions carried out by the assessee. 8.3. The final list of comparable as chosen by the ld. TPO are as under:- Sr. No. Name of the company

Deputy Commissioner of Income Tax Circle-7(1)(1), Bangalore vs. M/S Timken Engineering & Research India Private Limited, Bangalore

In the result, the appeal and cross objection filed by the assessee and the appeal of the revenue are treated as partly allowed for statistical purposes

ITA 694/BANG/2019[2011-12]Status: DisposedITAT Bangalore31 Jan 2022AY 2011-12

Bench: Shri George George K. & Shri B.R. Baskaranassessment Year:2011-12

For Appellant: Sri Aliasghar Rampurawala, A.RFor Respondent: Sri Pradeep Kumar, D.R

provision for roll- back of APA to three preceding assessment years, viz., 2013-14 to 2015-16. The Ld. A.R. submitted that the international transactions entered by the assessee during the year under consideration are similar to the international transactions that were entered during the years covered by APA. Accordingly ... same in favour of the assessee by restoring the issue to the file of the AO/TPO with a direction to ascertain the nature of international transactions that have been entered in the current year and if they are of similar nature as entered in the years covered by APA, then

M/S Timken Engineering and Research India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-5(1)(1), Bangalore

In the result, the appeal and cross objection filed by the assessee and the appeal of the revenue are treated as partly allowed for statistical purposes

ITA 517/BANG/2019[2011-12]Status: DisposedITAT Bangalore31 Jan 2022AY 2011-12

Bench: Shri George George K. & Shri B.R. Baskaranassessment Year:2011-12

For Appellant: Sri Aliasghar Rampurawala, A.RFor Respondent: Sri Pradeep Kumar, D.R

provision for roll- back of APA to three preceding assessment years, viz., 2013-14 to 2015-16. The Ld. A.R. submitted that the international transactions entered by the assessee during the year under consideration are similar to the international transactions that were entered during the years covered by APA. Accordingly ... same in favour of the assessee by restoring the issue to the file of the AO/TPO with a direction to ascertain the nature of international transactions that have been entered in the current year and if they are of similar nature as entered in the years covered by APA, then

Global E Business Operations Private Limited, Bangalore vs. DCIT, Bangalore

In the result, the revenue’s appeal is partly allowed for statistical purposes

ITA 418/BANG/2016[2011-12]Status: DisposedITAT Bangalore31 Jan 2022AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Sharath Rao, CAFor Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 10ASection 143(3)

turnover/service revenue while selecting the companies comparable to the Appellant for the purpose of determining the Arm’s Length Margin of the international transactions of the Appellant with its Associated Enterprises outside India in the Information Technology Enabled Services (ITES) segment. 4. The assessee in the petitions for admission ... revenue of Rs.1 crore, erred in not applying a cap on the upper limit on the turnover/service revenue while determining the ALP of the international transactions of the assessee with its AE in the ITeS segment. The ld. AR submitted that admission of the above additional grounds would be necessary

Asst.C.I.T., Bangalore vs. M/S Global E- Business Operations Pvt. Ltd., Bangalore

In the result, the revenue’s appeal is partly allowed for statistical purposes

ITA 250/BANG/2016[2011-12]Status: DisposedITAT Bangalore31 Jan 2022AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Sharath Rao, CAFor Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 10ASection 143(3)

turnover/service revenue while selecting the companies comparable to the Appellant for the purpose of determining the Arm’s Length Margin of the international transactions of the Appellant with its Associated Enterprises outside India in the Information Technology Enabled Services (ITES) segment. 4. The assessee in the petitions for admission ... revenue of Rs.1 crore, erred in not applying a cap on the upper limit on the turnover/service revenue while determining the ALP of the international transactions of the assessee with its AE in the ITeS segment. The ld. AR submitted that admission of the above additional grounds would be necessary

Bharti Airtel Services Ltd., New Delhi vs. DCIT, Circle-4(2), New Delhi

ITA 6272/DEL/2018[2012-13]Status: DisposedITAT Delhi31 Jan 2022AY 2012-13

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar(Through Video Conferencing)

For Appellant: S/Shri Rahul Mitra, NininFor Respondent: Shri Mrinal Kumar Das
Section 143(3)

assessee provides man-power equipment and related to services to Bharti Airtel Ltd. and its foreign AEs. Though there were other primary international transactions, the TPO has not taken any adverse inference in respect of primary transactions with the AE. However, TPO held that outstanding receivable from ... transaction; and secondly, if the TPO is separately bench marking transaction then it has to be benchmark using the aggregate approach with the principal international transaction entered with its AE and, in such scenario, the receivables are already factored in the price charged to the AE. Here in this case

Bharti Airtel Services Ltd., Gurgaon vs. DCIT, Circle-4(2), New Delhi

ITA 3183/DEL/2018[2013-14]Status: DisposedITAT Delhi31 Jan 2022AY 2013-14

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar(Through Video Conferencing)

For Appellant: S/Shri Rahul Mitra, NininFor Respondent: Shri Mrinal Kumar Das
Section 143(3)

assessee provides man-power equipment and related to services to Bharti Airtel Ltd. and its foreign AEs. Though there were other primary international transactions, the TPO has not taken any adverse inference in respect of primary transactions with the AE. However, TPO held that outstanding receivable from ... transaction; and secondly, if the TPO is separately bench marking transaction then it has to be benchmark using the aggregate approach with the principal international transaction entered with its AE and, in such scenario, the receivables are already factored in the price charged to the AE. Here in this case

Siemens Ltd, Mumbai vs. DCIT Cir 8(2)(1), Mumbai

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

ITA 1146/MUM/2018[2010-11]Status: DisposedITAT Mumbai28 Jan 2022AY 2010-11

Bench: Shri Pramod Kumar & Shri Pavan Kumar Gadalesiemens Ltd (Successor Vs. Dcit, In Interest To Siemens Corporate Circle - Building Technologies 8(2)(1), Pvt Ltd.,) Room No. 615, 6Th Birla Aurora, Level 20, Floor, Aayakar P.No. 1080, Ar. Annie Bhavan, Mk Road, Besant Road, Worli, Mumbai – 400020. Mumbai – 400030. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacs0764L Appellant .. Respondent

For Appellant: Shri. Nitesh Joshi. ARFor Respondent: Shri. Ajit Pal Singh.DR
Section 143(1)Section 143(2)Section 143(3)

along with the questionnaire was issued. The A.O on perusal of the facts found that the assessee has international transactions with its Associate Enterprises (AE) as per form.no.3CEB, more than the specified limits, therefore the matter was referred to the TPO for determination of Arms Length Price (ALP). Whereas

ACIT, Circle-11(2), New Delhi vs. Humboldt Wedag India Pvt. Ltd., New Delhi

In the result, a. Provision for liquidated damages is allowed

ITA 7147/DEL/2018[2009-10]Status: DisposedITAT Delhi28 Jan 2022AY 2009-10

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 7147/Del/2018 : Asstt. Year : 2009-10 Acit, Vs Humboldt Wedag India Pvt. Ltd., Circle-11(2), A-36, Mehtab House, Mohan Co- New Delhi Operative Industrial Area, Mathura Road, New Delhi-110044 (Appellant) (Respondent) Pan No. Aaach7474G Assessee By : Sh. S. K. Aggarwal, Ca Revenue By : Ms. Meenakshi J. Goswani, Cit Dr Date Of Hearing: 25.10.2021 Date Of Pronouncement: 28.01.2022

For Appellant: Sh. S. K. Aggarwal, CAFor Respondent: Ms. Meenakshi J. Goswani, CIT DR

equipments for cement and coal and mineral plants. During the current F.Y. 2008-09 relevant to this A.Y. 2009-10, the assessee company had international transactions with its Associated Enterprises (AEs) totaling to Rs.140,38,45,328/- on account of purchase of raw materials, transaction in respect of intangible property ... transaction in respect of services. The said international transactions were referred to the Transfer Pricing Officer (TPO) for determination of Arm’s Length Price and adjustment, if any, thereof. 1. Liquidated Damages: 5. The similar issue has been adjudicated in the case of the assessee

Luxottica India Eyewear Pvt. Ltd., Gurgaon vs. ACIT, Circle- 15(2), New Delhi

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

ITA 8259/DEL/2018[2014-15]Status: DisposedITAT Delhi27 Jan 2022AY 2014-15

Bench: Sh. Saktwit Dey & Sh. N. K. Billaiya

Section 143Section 92B

case and in law, the Hon'ble DRP/Ld. AO/Ld. TPO erred in assuming that the AMP expenditure incurred by the Appellant is an. "international transaction" within the meaning of the term as contained in section 92B of the Act (including the explanation to section 92B) without appreciating that ... have erred in using Transactional Net Margin Method ("TNMM") to determine the arm's length nature of the alleged international transaction by comparing the net margin earned by the Appellant with adjusted net margins of comparable companies ("intensity adjustment'), without giving any reasons for rejecting the Resale Price Method

Munjal Showa Ltd, Gurugram vs. JCIT, Special Range-6, New Delhi

In the result, appeal of the assessee in ITA No

ITA 8227/DEL/2018[2014-15]Status: HeardITAT Delhi27 Jan 2022AY 2014-15

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Ms. Sweta Gupta, CAFor Respondent: Shri Surender Pal, CIT-DR
Section 143(3)

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘I-1’ BENCH, NEW DELHI (THROUGH VIDEO CONFERENCING] BEFORE SHRI SAKTIJIT DEY, JUDICIAL

Xavient Information Systems (I) Pvt. Ltd., Noida vs. DCIT, New Delhi

The appeal of the assessee stands dismissed

ITA 472/DEL/2017[2010-11]Status: FixedITAT Delhi25 Jan 2022AY 2010-11
Section 120Section 127Section 143(1)Section 143(3)Section 92A(2)(b)

assessee was asked to file a copy of the Transfer Pricing Study report to justify the Arms’ Length Price of the assessee’s international transaction, in response to which, the assessee submitted that for the year under consideration, no transfer pricing study had been conducted. Subsequently, the assessment was Xavient

Asst. CIT-6 (2)(2), Mumbai vs. Enhance Ambient Communication Pvt Ltd., Mumbai

ITA 6285/MUM/2019[2013-14]Status: DisposedITAT Mumbai24 Jan 2022AY 2013-14

Bench: Shri Kuldip Singh & Shri Prashant Maharishiassessment Year: 2013-14

For Appellant: NoneFor Respondent: Shri Jayant Jhaveri, D.R
Section 271GSection 92CSection 92D(3)

assessee, the TPO levied a penalty of Rs.3,99,22,018/- being (Rs.2,17,27,118/- and Rs.1,81,94,900/- @ 2% of the international transaction amount and 2% of specific domestic transaction amount respectively) under section 271G of the Act. 4. The assessee carried the matter before ... assessee to furnish specific details under section 92C within the meaning of section 92D(3) of the Act in order to benchmark the international transactions entered into by the assessee with its AE. 8. In the backdrop of the aforesaid undisputed facts, the Ld. CIT(A) deleted the penalty

Tata Sons Ltd., Mumbai vs. DCIT Cir. - 2(3)(1), Mumbai

In the result, assessee’s appeal is partly allowed and revenue’s appeal is dismissed

ITA 6418/MUM/2016[2010-11]Status: DisposedITAT Mumbai21 Jan 2022AY 2010-11

Bench: Shri S.Rifaur Rahman ( & Shri Pavan Kumar Gadale ()

For Appellant: 1) Transfer Pricing Adjustment - Guarantee Fees
Section 115JSection 143(1)Section 143(3)Section 14ASection 37Section 92C

erred in not accepting that the guarantee given by the appellant on behalf of a wholly owned subsidiary, Tata Ltd. UK, is not an international transaction, as there is no cost and no bearing on profits, income, losses or assets of the Appellant. ii) The CIT(A) erred ... accepting the fact that providing corporate guarantee is a shareholder activity and therefore it is not an international transaction. iii) Without prejudice, the CIT(A) erred in confirming the guarantee fee at 0.822% p.a. instead of 0.25% p.a. without appreciating the facts and submissions made by the appellant. iv) Without

ACIT, Cir.-2(3)(1), Mumbai vs. Tata Sons Ltd., Mumbai

In the result, assessee’s appeal is partly allowed and revenue’s appeal is dismissed

ITA 6402/MUM/2016[2010-11]Status: DisposedITAT Mumbai21 Jan 2022AY 2010-11

Bench: Shri S.Rifaur Rahman ( & Shri Pavan Kumar Gadale ()

For Appellant: 1) Transfer Pricing Adjustment - Guarantee Fees
Section 115JSection 143(1)Section 143(3)Section 14ASection 37Section 92C

erred in not accepting that the guarantee given by the appellant on behalf of a wholly owned subsidiary, Tata Ltd. UK, is not an international transaction, as there is no cost and no bearing on profits, income, losses or assets of the Appellant. ii) The CIT(A) erred ... accepting the fact that providing corporate guarantee is a shareholder activity and therefore it is not an international transaction. iii) Without prejudice, the CIT(A) erred in confirming the guarantee fee at 0.822% p.a. instead of 0.25% p.a. without appreciating the facts and submissions made by the appellant. iv) Without

Swiss Re Global Business Solutions India Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-6(1)(2), Bangalore

In the result, the appeal of the assessee is partly allowed

ITA 397/BANG/2021[2016-17]Status: DisposedITAT Bangalore21 Jan 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Nageswar Rao, AdvocateFor Respondent: Shri Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 133(6)

read with the Rules, and in conducting a fresh economic analysis for the determination of the ALP in connection with the impugned international transactions and holding that the Appellant's international transactions are not at arm's length; 4. Learned AO / TPO / DRP have erred, in law and facts ... No.397/Bang/2021 Page 7 of 21 6. As per the Transfer Pricing (TP) document, the assessee company has entered into the following international transactions with its Associated Enterprises (AEs): Amount Amount Method International Transactions Received/Receivable Paid/Payable Provision of back office 1,76,41,00,100 TNMM support service Other Method Reimbursement

Societe Generale Global Solution Centre Pvt Ltd, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-6(1)(2), Bengaluru

In the result, the assessee’s appeal is partly allowed

ITA 2580/BANG/2017[2013-14]Status: DisposedITAT Bangalore21 Jan 2022AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri T. Suryanarayana, Sr. CounselFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 10ASection 115JSection 143(3)Section 271Section 274

Appellant to its Associated Enterprises, the same ought to be aggregated with the principal transactions, and ought not to be treated as an independent international transaction. 2(e). That the action of the TPO in comparing the Appellant with companies in tours and travel industry is erroneous in as much ... engaged in the services of the firm to prepare the transfer pricing memorandum documenting the review of the arm’s length nature of its international transactions with its AE during the year under consideration from an Indian transfer pricing perspective. It also provides software development services and IT enabled Services

ACIT, Circle- 6(1), New Delhi vs. Ch2M Hill (India) Pvt. Ltd., New Delhi

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

ITA 5525/DEL/2018[2014-15]Status: DisposedITAT Delhi21 Jan 2022AY 2014-15

Bench: Shri Amit Shukla & Dr. B.R.R. Kumar

For Appellant: Shri Ajit Jain, CAFor Respondent: Shri Mrinal Kumar Das, Senior DR
Section 143(3)Section 92C

parties. The return of income was filed declaring a total loss of INR 23,87,25,233/-. The assessee company had also entered into international transaction for which the reference was made to the Transfer Pricing Officer (TPO) to determine the Arm’s Length Price of such transaction u/s 92CA ... international transactions undertaken by the assessee during the year under consideration were essentially for rendering of technical consultancy services and availing of technical consultancy services. Details of international transaction as per Form No. 3CEB of the Assessee company were as under: S. Value Nature of Transactions Method Applied