*Income Tax - Transfer Pricing - Assessee's Appeal Allowed*
"Even though Ld DRP tried to distinguish the Bechtel India case, however, unless it is brought on record that this particular transaction falls within the framework of financial transaction, you cannot invoke the provisions mechanically." Assessee's appeal allowed.
*Standard and Poors South Asia Services Private Ltd v ACIT [2025] GCtR 679 (ITAT, Delhi)*
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