Ge India Industrial (P) Ltd.,, Haryana vs The Acit.,Kheda Circle,, Nadiad on 4 December, 2018
7.3. Our view is supported by ITAT judgments - Mumbai Bench in the
cases of UCB India (P) Ltd. Vs. ACIT (supra); and ACIT v. Star India Ltd.
(supra); and Kolkata Bench in the case of Development Consultants (P) Ltd.
(supra). All these cases clearly lay down that ALP would be determined
based on the nature of service provided by assessee for each class of
transaction based on various factors and analysis.