Shanti Prime Publication Pvt. Ltd.
Section 92CA of the Income Tax Act, 1961 – Transfer Pricing – Computation of arm's length price – Tribunal took into consideration the voluminous documentary evidence on record in the form of e-mail correspondence indicting the rendition of service and the Tribunal was right in its view that the assessee would be right person to know whether or not the devices were required and the rendition of services has not been disputed, thus, the decision of the Tribunal was correct and required no interference – Principal Commissioner of Income Tax vs. Tudor India P ltd (2019) 420 ITR 399 (Gujarat)