Tribunal held that and accordingly it is to be held that transfer pricing regulations do not apply to assessee to extent of operations carried out through operating qualifying ships where income is taxed under Tonnage Tax Scheme. (AY. 2007 -08)
Van Oord India (P.) Ltd. v. ACIT (2019) 177 ITD 687/ 183 DTR 151/ 292 TTJ 248 (Mum.)(Trib.)
S. 92 : Transfer pricing-Arm’s length price–Tonnage tax-Provisions of Chapter X (Transfer pricing) would have no application in computing income of assessee chargeable to tax as per Chapter XII-G (Tonnage tax scheme) [S. 115JB, 115VA]