TOYOTA BOSHOKU AUTOMOTIVE INDIA PRIVATE LIMITED,BIDADI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT OR THE DCIT, CIRCLE - 7(1)(1), KORAMANGALA

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

transfer pricing provisions, thereby warranting an Arm’s Length Price (ALP) determination. 16.1 The TPO rejected the assessee’s contention that the receivables transaction should not be separately benchmarked as it was part of an overall business arrangement with the AE. As such, the TPO noted that aggregation of transactions is permissible only when the underlying transactions are continuous, closely