PCIT v. Boeing India Pvt. Ltd.[2024] 297 Taxman 225 (SC). Editorial : PCIT v. Boeing India Pvt. Ltd. (2023)457 ITR 84/146 taxmann.com 131 (Delhi)(HC)

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-SLP of Revenue is dismissed.[Art. 136]

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. SLP of Revenue is dismissed. (AY. 2015-16)