PR.COMMISSIONER OF INCOMETAX-2 vs. M/S.EYGBS (INDIA) PVT LTD

Bench: CHIEF JUSTICE,C M JOSHI

TP adjustments are made pursuant to the APA entered into by the Assessee with CBDT. Section 92CC of the Act empowers the CBDT (Central Board of Direct Taxes) to enter into an APA (Advance Pricing Agreement) with any person for determining an ALP or specify the manner in which the ALP is to be determined, in relation to an international

THE PR. COMMISSIONER OF INCOME TAX vs. M/S. ACER INDIA PVT LTD

Bench: S.SUJATHA,VINEET KOTHARI