I.C.SUDHIR, J. - (1.)
(2.) THE Revenue has questioned First Appellate Order raising the issue as to whether the Learned CIT(Appeals) under the facts and circumstances of the case and in law is justified in deleting the addition of Rs. 61,62,871 made by Assessing Officer/TPO on account of difference in arm's length price (ALP) of international transaction. We have heard and considered the arguments advanced by the parties in view of orders of the authorities below, material available on record and the decisions relied upon.
(3.) THE facts in brief are that the assessee is a private limited company registered in India and is a wholly owned subsidiary of Danisco A/S, Denmark. The assessee was incorporated on 21.1.1991 for manufacturing and marketing of food and non -food ingredients. M/s. Denisco India is primarily engaged in manufacturing of artificial flavors, food and non -food ingredients and trading of ingredients.;