In the result, appeal of the assessee in ITA No
Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपीऱ सं. / Ita No.714/Pun/2011 नििाारण वषा / Assessment Year : 2005-06 The Assistant Commissioner Of Income Tax, Circle-1, Aurangabad. .......अऩीऱाथी / Appellant बिाम / V/S. Skoda Auto India Pvt. Ltd. Plot No.A1/1, Shendra Five Star Industrial Area, Midc, Aurangabad-431 201 Pan :Aaecs3749M ……प्रत्यथी / Respondent
B)(3)] prescribe that in order to make comparability meaningful and the conditions prevailing in the market in which the tested party and comparables operates have to be considered while judging comparability of an international transaction with an uncontrolled transaction and suitable adjustments have to be made to eliminate the material effects of such differences. In view of the above