https://www.taxtmi.com/caselaws?id=446775 ITAT Delhi allowed the assessee's appeal and deleted the transfer pricing adjustment made by the AO. The assessee, incorporated in March 2017, had no business operations during FY 2016-17 and no TPO reference was made. The AO erroneously applied TPO findings from Boeing Corporation India Ltd. (BCIL) to make identical additions against the assessee. Since BCIL merged with the assessee only on April 1, 2017, it remained an independent entity until March 31, 2017. The international transaction in question was undertaken by BCIL, not the assessee, making the assessment order liable to be quashed. en-us Fri, 08 Dec 2023 00:00:00 +0530 Mon, 11 Dec 2023 08:59:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446775 ITAT Delhi allowed the assessee's appeal and deleted the transfer pricing adjustment made by the AO. The assessee, incorporated in March 2017, had no business operations during FY 2016-17 and no TPO reference was made. The AO erroneously applied TPO findings from Boeing Corporation India Ltd. (BCIL) to make identical additions against the assessee. Since BCIL merged with the assessee only on April 1, 2017, it remained an independent entity until March 31, 2017. The international transaction in question was undertaken by BCIL, not the assessee, making the assessment order liable to be quashed. Case-Laws Income Tax Fri, 08 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446775