The Tribunal held that since the issue was already covered by the Tribunal in the assessee’s own case and the Department had failed to suggest any exception on facts or law involved in the assessment year under consideration, the detailed reasoning given by the Tribunal was to be adopted. (AY. 2014-15)
ACIT v. Manaksia Ltd. (2022)97 ITR 433 (Kol) (Trib)
S. 92C: Transfer pricing-Arm’s length price-Comparable uncontrolled price method-Interest earned on loan to associated enterprise-Justified in deleting addition. [S.92CA]