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2016 (10) TMI 1048 - HC - Income TaxExclusion of the three comparables in the transfer pricing exercise conducted by the revenue - exclusion was on the ground that in respect of each comparable, certain extraordinary events had occurred during the previous periods which distorted the profitability thereby increasing the margin. Held that:- Quite apart from the fact that tribunal’s findings cannot be characterised as unreasonable, this court also notices that even if the figures of comparables were to be included, no adjustment would be permissible due to the fact that the margin of variation would be within the limits of the “Safe Harbour Provision” embodied in the Rules framed by the board in exercise of its power under Section 92CA(3). In the circumstance, no questions of law arises, the appeal is dismissed.
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