M/S INSTRUMENTARIUM CORPORATION LTD.,KOLKATA vs. DDIT (IT)-1(1), KOLKATA, KOLKATA

Bench: The Special Bench:

transfer provisions of the Act, it is difficult to evaluate the overall revenue effect in those situations. Accordingly, the approach in paragraphs 16 and 17 of this Ruling should be followed with no determination and adjustment under subsection 136AD(2). I.T.A. Nos.1548 and 1549/Kol/2009 Assessment years: 2003-04 and 2004-05 Page 26 of 41 23. It is important

DONGFANG ELECTRIC CORPORATION,KOLKATA vs. DCIT, INTERNATIONAL TAXATION 1(1), KOLKATA, KOLKATA

In the result, both the appeals of the assessee are allowed

Bench: Sri N.V. Vasudevan & Sri J. Sudhakar Reddy]

Transfer Pricing Officer (TPO). 5.1. The ld. Counsel for the assessee, Shri Nageswar Rao, argued that, no reference was made by the ld. Assessing Officer, to the ld. TPO for 14 I.T.A. No. 572/Kol/2014 Assessment Year: 2009-10 & I.T.A. No. 487/Kol/2015 Assessment Year: 2010-11 Dongfang Electric Corporation determination of Arms Length Price of any international transaction and hence