https://www.taxtmi.com/caselaws?id=345893 The Tribunal held that the assessee and its foreign supplier were not associated enterprises under section 92A because the Revenue's relied-upon clauses did not fit the facts: the supplier merely purchased rough diamonds for onward supply, and the record did not show the required control, shareholding, or other qualifying interest relationship between the two partnership firms. As transfer pricing provisions could not be invoked without such a relationship, the arm's length price adjustment made under section 92CA(3) was deleted and that deletion was sustained in favour of the assessee. en-us Tue, 20 Jun 2017 00:00:00 +0530 Tue, 16 Oct 2018 12:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=345893 The Tribunal held that the assessee and its foreign supplier were not associated enterprises under section 92A because the Revenue's relied-upon clauses did not fit the facts: the supplier merely purchased rough diamonds for onward supply, and the record did not show the required control, shareholding, or other qualifying interest relationship between the two partnership firms. As transfer pricing provisions could not be invoked without such a relationship, the arm's length price adjustment made under section 92CA(3) was deleted and that deletion was sustained in favour of the assessee. Case-Laws Income Tax Tue, 20 Jun 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=345893