Tribunal held that data to be used for comparison should be data relating to same financial year in which international transaction were entered by tested party. Order of DRP is affirmed. Delay of 47 days in filing appeal by the revenue was condoned (AY. 2009-10)
Firemenich Aromatics (I) (P) Ltd. v. ACIT (2020) 184 ITD 43 (Mum.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Comparison-Data should be of same financial year-Delay of 47 days in filing appeal by the revenue was condoned. [S. 253]