Held that since market quotes were available on corresponding dates and when corresponding data was not available on the date of contract entered between the assessee and its associated enterprise, the “other method” had been rightly applied by the assessee. The Transfer Pricing Officer has failed to analyse the transfer pricing documentation prepared by the assessee. The assessee had considered all the market quotations available while maintaining the transfer pricing report and considering the contemporaneous nature of documentation process as provided under the relevant provisions of the Act. That the documentation of arm’s length price by the assessee by adopting quotations from various brokerage houses, associations and exchanges could not be faulted. Addition is deleted. (AY.2018-19)
Golden Agri Resources (India) P. Ltd. v.Asst. CIT (OSD) (2024)113 ITR 496 (Delhi)(Trib)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Most appropriate method-Variation is not a ground to reject assessee’s Transfer Pricing analysis.[S.92CA]
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