M/S PALMER INVESTMENT GROUP LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-2(1), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

Section 92A(2) of the Act, and such disclosure does not take away the arm's length nature of the arrangement entered into between two third parties. 5. The learned AO, the learned TPO, and the Hon'ble DRP have erroneously concluded that the Appellant had entered into an arrangement with Relay B.V to transfer controlling stake in United Spirits