2019 (8) TMI 512

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....cal questions of law are urged by the Revenue in two appeals against the same assessee. The question is whether in the absence of interest, claimed from an Associated Enterprises, (A.E.) notional amounts could be attributed in the income and adjusted to the assessee's accounts in the Arm's Length Price (ALP) determination, under Section 92CA(3) of the Income Tax Act, 1961. 2. The assessee's incom....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... reliance was placed upon the Pr. CIT vs. B.C.  Management Services (P) Ltd. [(2018) 403 ITR 45 (Del)], Pr. CIT, Alwar Vs. M/s. Gillette India Ltd. [DB ITA No.341/2017 decided on 06.02.2018]. In B.C. Management Services (P) Ltd (Supra), the Court had held following Principal CIT vs. Bechtel India (P) Ltd. [IT Appeal No. 379/2016 decided on 21.07.2016] that such notional income on account of d....