PCIT v. Boeing India Pvt. Ltd. (2023)457 ITR 84/146 taxmann.com 131 (Delhi)(HC) Editorial: SLP dismissed, PCIT v. Boeing India Pvt. Ltd.[2024] 158 taxmann.com 214 (SC). Affirmed, Boeing India Pvt. Ltd v. ACIT (2020) 81 ITR 94 (Delhi)(Trib)

S. 92CA : Transfer pricing-Reference to Transfer Pricing Officer-Arm’s Length price-No interest was paid to creditor or supplier nor any interest has been earned from unrelated party-Deletion of addition by the Tribunal is affirmed. [S. 260A]

Held that  the Tribunal had deleted the transfer pricing adjustment on account of receivables holding that the assessee was a debt-free company and that no interest was paid to the creditor or supplier nor any interest had been earned from unrelated party. Being a 100 per cent. captive service provider, the revenue of the assessee was 100 per cent. from its associated enterprises. Order of Tribunal is affirmed. (AY. 2015-16)