Dismissing the appeal of the revenue the Court held that , addition deleted by the Tribunal considering the difference in function performed and risk undertaken and also difference in brokerage charged to related and un related parties being question of fact .( AY.2002-03)
CIT v. J.P.Morgan India ( P) Ltd ( 2018) 161 DTR 398/ 304 CTR 686 ( Bom) (HC)
S.92C: Transfer pricing – Arm’s Length Price – Difference in function performed and risk undertaken – Difference in brokerage charged to related and un related parties –Deletion of addition was held to be justified