Held that the Safe Harbour notification dated September 18, 2013, relied upon by the Revenue was prospective and did not apply to the assessment year in question. Even otherwise the decisions relied upon by the Tribunal in the order covered this issue in favour of the assessee as far as the assessment year in question was concerned.. Order of Tribunal is affirmed. (AY. 2009-10)
PCIT v. Fiserv India Pvt. Ltd. (2024)470 ITR 145 (Delhi)(HC)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparable-Gains arising due to fluctuation in rate of foreign exchange-Income-safe harbour
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