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2022 (12) TMI 156 - AT - Income TaxTransfer Pricing adjustment. - international transaction of the assessee-company with its AEs representing the sale of resins - HELD THAT:- Restriction of Transfer Pricing adjustment only in respect of the relevant international transaction of the assessee-company with its AEs representing sale of resins is squarely covered by various judicial pronouncements including the decision of Delhi Bench of this Tribunal in the case of Aithent Technologies (P.) Ltd. [2015 (2) TMI 535 - ITAT DELHI] relied upon by the Ld.CIT(A) in his impugned order. DR has also not been able to dispute this position. He has also not cited any case-law which is in favour of Revenue on this issue. We, therefore, respectfully follow the decision of Coordinate Bench of this Tribunal in the case of Aithent Technologies (P.) Ltd. (supra) and uphold the impugned order of the Ld.CIT(A) directing the Assessing Officer to restrict the Transfer Pricing adjustment only in respect of international transaction of the assessee-company with its AEs representing the sale of resins. Appeal of the Revenue is dismissed.
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