TATA CUMMINS PRIVATE LIMITED,PUNE vs. THE DCIT CIRCLE-1-JAMSHEDPUR AND THE ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, NFAC, DELHI, JAMSHEDPUR

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaytata Cummins Private Limited, D.C.I.T., Cummins India Office, Tower-A, 7Th Circle-1, Vs. Floor, Survey No. 21, Balewadi, Pune, Jamshedpur. Maharashtra. Pan No. Aaact 6353 L Appellant/ Assessee Respondent/ Revenue

transfer pricing adjustment in respect of such transaction Chapter X does not arise and therefore, question (3) is answered in the negative and in favour of the Assessee and against the Revenue." vi. Bausch & Lomb Eyecare India Pvt Ltd [ITA 63/2014] The relevant extract for the same is as follows: "There is merit in the contention of the Assessee that