Bareboat Charter Payments to AE Held at Arm’s Length When Key Functions and Risks Lie with Indian JV Mumbai ITAT deletes TP adjustment on bare‑boat charter hire in SP Armada Oil Exploration for AY 2021‑22 Introduction: In the case of SP Armada Oil Exploration Private Limited v. Deputy Commissioner of Income Tax – Circle 3(3)(1), Mumbai (ITA No. 6575/Mum/2024 for AY 2021‑22), the…
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