ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, DIBRUGARH vs. GREENPLY INDUSTRIES LIMITED, KOLKATA
In the result, the appeal of the Revenue is dismissed
ITA 140/GTY/2024[2013-14]Status: DisposedITAT Guwahati15 Dec 2025AY 2013-14
Bench: Shri Rajesh Kumar, Am & Shrimanomohan Das, Jm Greenply Industries Ltd Acit, Circle-1 Madgul Lounge, 5 Th Floor, 23 Aaykar Bhawan, Milan Nagar, Chetiacental Road, Kolkata- Vs. Dibrugarh-786001, Assam 700027, West Bengal (Appellant) (Respondent) Pan No. Aaacg7284R Assessee By : Shri Ashok Tulsyan, Ar Revenue By : Shri Sanjay Jha, Dr Date Of Hearing: 02.12.2025 Date Of Pronouncement: 15.12.2025
For Appellant: Shri Ashok Tulsyan, ARFor Respondent: Shri Sanjay Jha, DR
Section 115J
Transfer Pricing Guidelines 2010 supports this view in para 7.13 where it is explained that where higher credit rating of Associated Enterprise is due to a guarantee by another group member, such association positively enhances the profit making potential of that Associated Enterprise. We, therefore, find ourselves in agreement with the contention of the Id. D.R. that there
