Shanti Prime Publication Pvt. Ltd.
Sec. 92, 92B, 92C of Income Tax Act, 1961—Transfer Pricing - The dispute in the present appeal hovers around the addition made of Rs. 3,23,85,404, on account of transfer pricing adjustment to the arm’s length price of the services provided to the Associated Enterprises (AE). The Tribunal while partly allowing the appeal o the assessee held that “we do not intend to deliberate further on any other comparable at this stage and leave the issues relating to the comparability of the other comparables open for adjudication if they arise in assessee’s case in any other assessment year in future. The AO is directed to determine the arm's length price of the international transaction with the AEs keeping in view our observations herein above”. - KHAZANAH INDIA ADVISORS PVT. LTD. V/s DEPUTY CIT -  184 ITD 890 (ITAT-MUMBAI)