M/S LANDIS+GYR LIMITED,,KOLKATA vs. DCIT, CIRCLE -1, KOLKATA, KOLKATA
In the result, the appeals of the assessee in ITA No
ITA 1623/KOL/2012[2008-2009]Status: DisposedITAT Kolkata03 Aug 2016AY 2008-2009
Bench: Shri M. Balaganesh, Am & Shri S. S. Viswanethra Ravi, Jm]
For Appellant: Shri Rahul Mitra, ARFor Respondent: Shri G. Mallikarjuna, CIT, DR
Section 144C(5)Section 144C(8)Section 43B
68 taxmann.com 322 (Delhi Trib.) is very well founded wherein the concept of overseas tested party and foreign comparable companies for determination of Arm’s Length
Price has been accepted. It was held as under:-
33. Ld. AR has cited many decisions, which are on the principle of selection of tested party, which is least complex