Taj Tv Ltd., Mumbai vs Dy Cit (International ... on 31 March, 2023
043. While holding so, we are conscious of the fact that in case of
decision of the Honourable Bombay High Court in case of Set
satellite (Singapore) PTE Ltd versus Deputy Director Of
International Taxation(2008) 307 ITR 205/173 taxman 475 (Bom)
and CIT versus B4U international Holdings Ltd (2015) 374 ITR 453 as
well as in assessee‟s own case coordinate bench in 77 taxmann.com
355 for assessment year 2006 - 07 to 2008 - 09 dated 23 December
2016 has categorically held that no income could be said to be
attributable to assessee, a foreign entity , in India from its Indian
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ITA No. 821/Mum/2021
Taj TV Ltd.; A.Y. 17-18
subsidiary when transfer pricing officer had accepted that the
transaction between them was at arm‟s-length.