2017 (7) TMI 1346

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.... JJ. Ms. Rashmi Chopra, Advocate For The Appellant. Mr. Asheesh Jain, Senior Standing Counsel For The Respondent. ORDER CM No.25169/2017 (delay in filing) in ITA No.524/2017 1. For the reasons as stated in the application, the delay in filing is condoned.  The application stands disposed of.    CM No.25168/2017 (exemption) in ITA No.524/2017 2. Allowed, subject ....

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....18 (Del) and also some of the subsequent judgments where the Court has held that in matters of transfer pricing the first exercise that is to be undertaken is to determine if in fact there existed an international transaction between the Assessee at its Associated Enterprise. Only if the said question is answered in the affirmative, the further question of determining its arm's length price would ....