Held, that no cost had been borne by the assessee-company and in the absence of any rebuttal to the assertion that actual bank commission charges incurred had been fully recovered from the associated enterprise, there is no justification in the transfer pricing adjustment. Addition is deleted. (AY. 2017-18
Bhartiya International Ltd. v. Dy. CIT (2024) 112 ITR 207/227 TTJ 897 (Delhi)(Trib)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Commission on standby letter of credit-No cost is incurred-Adjustment is deleted.