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2023 (7) TMI 845 - ITAT AHMEDABADIncome accrued in India - assessee held 90% shares of a company based in UAE namely M/s. Rubamin FZC (RFZC) - Taxing entire profit of RFZC, UAE as profit belonging to the assessee - HELD THAT:- As decided in favour of assessee as in own case [2021 (10) TMI 506 - ITAT AHMEDABAD] wherein held that profit attributable to RFZC with respect to the transactions carried out by it with the company based in China namely Trafigura Beheer BV belongs to DRC companies. Likewise, the profit attributable to RFZC with respect to the transactions carried out by it with the assessee company has already been subject to transfer pricing provisions. Therefore, no inference can be drawn that the profit of the assessee company got diverted. Hence the ground of appeal of the assessee is allowed.
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