TOPSGRUP ELECTRONICS SYSTEMS LTD,MUMBAI vs. ITO WD 8(3)(3), MUMBAI

In the result, the assessee’s appeal for assessment year 2009-10 is allowed as indicated above

Bench: Shri Jason P. Boaz & Shri Amit Shuklam/S. Topsgrup Electronic Systems Income Tax Officer-8(3)(3) Ltd. (Previsously Tops Sequipment Ltd.) Àayakar Bhavan, M.K. Road 5, Royal Palms Golf & Country Club Vs. Mumbai 400020 Aarey Milk Colony, Goregaon (E) Mumbai 400065 Pan - Aaact3291K Appellant Respondent

VB, Netherlands. It was submitted by the assessee that while this transaction is admittedly an international transaction under section 92B of the Act, however no income has arisen out of this transaction. Therefore, the learned A.R. for the assessee submitted that in the absence of income, this transaction is not required to be benchmarked and the same is beyond