SKF TECHNOLOGIES (INDIA) PRIVATE LIMITED,BANGALORE vs. ACIT, BANGALORE

Bench: Shri. Abraham P. George

section 37 in this case. Indeed, this is not to say that the Transfer Pricing Officer cannot—after a consideration of the facts—state that the arm's length price is 'nil' given that an independent entity in a comparable transaction would not pay any amount. However, this is different from the Transfer Pricing Officer stating that the assessee

M/S CAE FLIGHT TRAINING (INDIA) PRIVATE LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, Both the C