In a recent ruling in case of Gharda Chemicals Limited, interesting questions were raised before the Mumbai Bench of the Income-tax Appellate Tribunal (ITAT), the second appellate and the last fact finding authority in Indian judiciary.

The taxpayer was an entity engaged in the manufacture of the agro-chemicals. During the year under consideration the taxpayer had exported a chemical named Dicmba to its associated enterprise (AE) in the US, for further resale to the ultimate customers in US.