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)
35A placed before DRP.
―C. Internal CUP preferred over external CUP
"5.26 It is important to note that the transactions entered into by associated enterprises with unrelated Party (―internal comparables‖) would provide more reliable and accurate data as compared to transactions by and between third parties ("external comparables").
OECD's Guidelines on Transfer Pricing recognize the fact that external comparables
