https://www.taxtmi.com/caselaws?id=327058 ITAT Mumbai held that issue of shares at a premium to a non-resident holding company does not, by itself, constitute an international transaction, so Chapter X could not be invoked to impute deemed loan or notional interest. On the import transactions, the Tribunal accepted the assessee's nearest-date CUP benchmarking and found that the transfer pricing authorities had relied on unsuitable comparables and dates, selectively ignored accepted data, and overemphasised unsupported volume differences. The transfer pricing adjustments were therefore deleted and the assessee's appeal was allowed. en-us Wed, 27 Apr 2016 00:00:00 +0530 Mon, 02 May 2016 00:36:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327058 ITAT Mumbai held that issue of shares at a premium to a non-resident holding company does not, by itself, constitute an international transaction, so Chapter X could not be invoked to impute deemed loan or notional interest. On the import transactions, the Tribunal accepted the assessee's nearest-date CUP benchmarking and found that the transfer pricing authorities had relied on unsuitable comparables and dates, selectively ignored accepted data, and overemphasised unsupported volume differences. The transfer pricing adjustments were therefore deleted and the assessee's appeal was allowed. Case-Laws Income Tax Wed, 27 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327058