THE ACIT, 1(1), BHOPAL vs. M/S. ANDRITZ HYDRO PVT. LTD., RAISEN

In the result, grounds taken by the assessee in all the years with respect to provision of warranty are allowed

Bench: Shri D.T. Garasia & Shri O.P. Meena

10A (d), and even the OECD guidelines, the only transaction, which are similar in nature or closely interlinked can be aggregated as one transaction and benchmarked, and only where considering it as separate transaction is impractical. Such is not the case here. Since all the AE projects of the assessee are independent and different projects, the benchmarking needs