https://www.taxtmi.com/caselaws?id=249830 The note addresses transfer pricing treatment of lease rentals for dredging equipment. It holds that transactions with different associated enterprises cannot be clubbed as closely linked or continuous for ALP determination; aggregation is permissible only for transactions between the assessee and each associate enterprise separately, and AO/TPO must determine ALP by aggregating per associate enterprise accordingly. On lease rentals paid beyond the project period for demobilization and redelivery, no conclusive standard or comparable evidence was produced by either party, and neither met the onus to establish ALP; the question whether such post-project rentals are acceptable must be resolved by comparing independent comparable transactions, and the matter is remitted to AO/TPO for reconsideration. en-us Fri, 18 Jul 2014 00:00:00 +0530 Sat, 24 Jan 2026 11:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=249830 The note addresses transfer pricing treatment of lease rentals for dredging equipment. It holds that transactions with different associated enterprises cannot be clubbed as closely linked or continuous for ALP determination; aggregation is permissible only for transactions between the assessee and each associate enterprise separately, and AO/TPO must determine ALP by aggregating per associate enterprise accordingly. On lease rentals paid beyond the project period for demobilization and redelivery, no conclusive standard or comparable evidence was produced by either party, and neither met the onus to establish ALP; the question whether such post-project rentals are acceptable must be resolved by comparing independent comparable transactions, and the matter is remitted to AO/TPO for reconsideration. Case-Laws Income Tax Fri, 18 Jul 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=249830