Held that the assessee’s contentions that Bloomberg database was not reliable or that the assessee’s export price was more than the Indian Customs quoted rate and accordingly, that the exports were at the arm’s length price even under the comparable uncontrolled price method had not been controverted by the Department. The Tribunal also rejected the reasons given by the Transfer Pricing Officer that the assessee had made arbitrary adjustment to the prices quoted by the indices with the intention to bring them to the tolerance level of +/- five per cent. It accepted the scientific calculation given by the assessee to arrive at the prices. The Tribunal had arrived at its conclusion on factual basis with valid reasons circumstances, there was no reason to interfere.(AY.2009 10- 2012-13)
PCIT v. Phoenix Comtrade Pvt. Ltd [2024] 162 taxmann.com 99 ( /(2025) 477 ITR 498 (Bom)(HC)
S. 92C : Transfer pricing – Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Arm’s length price-No substantial question of law.[S. 260A]
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