Income Tax Officer vs Maruti Countrywide Auto Financial ... on 20 December, 2007
4. ITO Vs. CRM Services India P. Ltd., 14 Taxman
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The above principles have also been upheld in the Indian Transfer
Pricing context in the case of Development Consultants Pvt.
Ltd. Vs. DCIT [2008, 23 SOT 455, Kol], Ranbaxy Laboratories
Limited vs ACIT (110 ITD 428) and Global Vintage Pvt Ltd vs.
DCIT [ 1 ITR (TRIB) 326, Delhi 2010]
5.1 Approach adopted by the Learned TPO in selecting the
Tested Party
In passing the transfer pricing order, the TPO has considered
MPAS as the tested party on the basis that MPL is more complex
of the two entities. In arriving at this conclusion, the TPO has
made the following observations in the impugned TP order:
Section 92 in The Income Tax Act, 1961 [Entire Act]
Section 92C in The Income Tax Act, 1961 [Entire Act]
Section 144C in The Income Tax Act, 1961 [Entire Act]
The Income Tax Act, 1961
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