Solex Chemicals Private Limited Vs. DCIT, Circle-7(1), Kolkata

Parties Involved

Facts Summary

Solex Chemicals Private Limited, an MSME and a wholly owned subsidiary of an Italian company, manufactures ingredients for household insecticides. The company purchases raw materials from a Chinese supplier through its Associate Enterprise, Endura S.P.A. The appeal was filed against the order of the National Faceless Assessment Centre, Delhi, passed under sections 143(3), 144C(13), and 144B of the Income Tax Act, 1961, for the Assessment Year 2021-22. The assessee raised several grounds of appeal, including the rejection of the Comparable Uncontrolled Price method and the selection of the Transactional Net Margin Method, failure to consider the Transfer Pricing report and revised form 3CEB, and incorrect computation of operating revenue and transfer pricing adjustment.…

Legal Issues

• 1. Rejection of the Comparable Uncontrolled Price method and selection of the Transactional Net Margin Method.
• 2. Failure to consider the Transfer Pricing report and revised form 3CEB.
• 3. Incorrect computation of operating revenue.
• 4. Incorrect computation of transfer pricing adjustment.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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