9 results for “transfer pricing”+ Section 36(2)clear
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In the result, both the appeals of the Revenue are dismissed
Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar U.S.
2)(b) of the Act. Further, the appellant has also submitted the judgements in the case of group concerns of the appellant, wherein the Hon'ble Gujarat High Court has justified the deletion of addition on these grounds by the Hon'ble ITATS. Thus the Honourable Gujarat High court, took into consideration the Commercial Expediency of the Borrowing and belon