OCEAN INDIA PVT. LTD.,,VISAKHAPATNAM vs. THE ACIT,, VISAKHAPATNAM
In the result, appeal filed by the assessee is allowed
ITA 150/VIZ/2016[2011-12]Status: DisposedITAT Visakhapatnam23 Nov 2020AY 2011-12
Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Blei.T. (T.P.) A. No. 150/Viz/2016 (Asst. Year : 2011-12) M/S. Teejay India Pvt. Ltd. Vs. The Acit, Circle-5(1), (Formerly Known As Ocean Visakhapatnam. India Pvt. Ltd.), Plot No. 15, Brandix India Apparel City Pvt. Ltd. Sez, Pudimadaka Road, Atchutapuram, Visakhapatnam. Pan No. Aaaco 9452 H (Appellant) (Respondent)
For Appellant: Shri Ajith Tolani/For Respondent: Shri D.K.Sonowal, CIT(DR)
Section 143(3)Section 92C(3)
section 92C(3) of the Act for determining the arm's length price for international transaction in relation to sale of finished goods and purchases of raw materials to/from its AEs.
3.4. Upholding the learned TPO's approach of using data which was not contemporaneous and which was not available in the public domain at the time of conducting
