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TMI Blog2024 (3) TMI 1378X X X X Extracts X X X X X X X X Extracts X X X X ..... ation for the inordinate delay except for stating certain administrative grounds. On perusal of the order passed by the learned Tribunal, impugned in this appeal, we find that the learned Tribunal has taken note of the decision of Almatis Alumina Pvt. Ltd [ 2022 (2) TMI 1063 - CALCUTTA HIGH COURT] The correctness of the said decision was challenged by the revenue before this Court and in the case ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... USTICE SUPRATIM BHATTACHARYA Mr. Vipul Kundalia, Adv. Mr. Amit Sharma, Adv. For the Appellant Mr. Pratyush Jhunjhunwalla, Adv. Ms. Sretapa Sinha, Adv. For the Respondent ORDER The Court : We have heard Mr. Vipul Kundalia, learned standing Counsel appearing with Mr. Amit Sharma, learned Advocate for the appellant department and Mr. Pratyush Jhunjhunwalla, learned Counsel for the respondent assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lines issued by the Institute of Chartered Accountants of India vide guidance note on report under section 92E by ICAI and transfer pricing guidelines issued by OECD the issue was whether it prohibits a foreign associate enterprise (AE) to be a tested party. This issue was considered by this Court in the case of Principal Commissioner of Income-tax 1 vs. ITC Infotech India Ltd., reported in (2024) ..... X X X X Extracts X X X X X X X X Extracts X X X X
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