Tribunal held that no ALP adjustment in respect of similar payments was made for assessment years 2001-02, 2002-03 and 2003-04 and that relief granted by Commissioner (Appeals) on this point when adjustments were made in assessment year 2004-05 had not been challenged. Adjustment was deleted. (AY. 2005-06)
SS Oral Hygine Products (P) Ltd. v. Dy. CIT (2022) 220 TTJ 939 / 145 taxmann.com 285 (Mum)(Trib)
S. 92C : Transfer pricing-Arm’s length price-Technical service fee-Relief granted for AY. 2004-05 was not challenged-Addition was deleted. [S. 92CA]