In the result, the appeals of the assessees in ITA Nos
Bench: S/Shri Chandra Poojari, Am&George George K., Jm
Section 40A(2). Hence, there was no shifting of profits in favour of sister concerns for their benefit as the transfer price was based on ultimate export price obtaining for respective grade(s) which therefore, constituted ALP on the date of relevant export contract. I.T.A. Nos.37 to 49/Coch/2016 8.7 It cannot stand to reason that the sale price of cashew