2024 (3) TMI 1378

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... Sharma, Adv. For the Appellant Mr. Pratyush Jhunjhunwalla, Adv. Ms. Sretapa Sinha, Adv. For the Respondent ORDER The Court : We have heard Mr. Vipul Kundalia, learned standing Counsel appearing with Mr. Amit Sharma, learned Advocate for the appellant department and Mr. Pratyush Jhunjhunwalla, learned Counsel for the respondent assessee. There is a delay of 1367 days in filing the appeal. We .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... f India vide guidance note on report under section 92E by ICAI and transfer pricing guidelines issued by OECD the issue was whether it prohibits a foreign associate enterprise (AE) to be a tested party. This issue was considered by this Court in the case of Principal Commissioner of Income-tax 1 vs. ITC Infotech India Ltd., reported in (2024) 159 taxmann.com 323 (Calcutta). Thus, we find that apa .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X