Held that sale of low volume of exports cannot be considered as valid comparable. Adjustment made adopting the ALP of interest at six moths average of LIBOR plus 3. 5 % % is not sustainable. (AY. 2005-06)
Ambuja Cement Ltd v Addl. CIT (2023) 223 TTJ 427 (Mum)(Trib)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparable-Sale of low volume of exports cannot be considered as valid comparable-Adjustment made adopting the ALP of interest at six moths average of LIBOR plus 3. 5 % % is not sustainable.