In the result, the appeal filed by the Assessee stands partly allowed for statistical purposes
Bench: Shri Inturi Rama Rao, Am& Shri Rahul Chaudharyit (Tp) A No. 119/Coch/2016 (Assessment Year: 2011-12) & It (Tp) A Nos. 38 & 643/Coch/2017 (Assessment Years :2012-13 & 2013-14)
transfer pricing provisions are attracted. The DRP failed to note that the assessing authorities had not established that AIRas was an associated enterprise within the meaning of explanation to section 92A(2