Tribunal held that while deciding the issue in the assessment year 2002-03 the Tribunal after considering all factual as well as legal aspects of the issue, had accepted the price charged by the assessee towards manning services to its associated enterprise to be at the arm’s length.(AY.2003-04)
Wilhelmsen Ship Management India Pvt. Ltd. v .Dy. CIT (2020) 81 ITR 14 (SN) ( Mum) (Trib)
S.92C: Transfer pricing — Arm’s length price — Manning service fee —Addition is deleted .