82 results for “transfer pricing”+ Section 801Bclear
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In the result, appeal filed by the learned assessing officer is dismissed
Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm
transfer pricing analysis and the OECD Guidelines which advocates aggregation of transactions under certain circumstances. 1.2 The CIT (A) erred in confirming addition made by the AO by way of adjustment on account of interest in respect of interest free advances made by the appellant to its 100% subsidiaries by estimating notional interest at 8.25% without considering the submissions made