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2017 (8) TMI 1417 - HC - Income TaxTPA - ALP determination - non-applicability of CUP method - comparability - Held that:- Companies functionally dissimilar with of assessee need to deselected from final list. See THE COMMISSIONER OF INCOME TAX, ALWAR. VERSUS M/S SAKATA INX (INDIA) LIMITED [2017 (7) TMI 1161 - RAJASTHAN HIGH COURT] Finding of the comparable to be adopted to determine the ALP as the basis of the activity conducted by the respondent-assessee is essentially a finding of fact. The view taken by the Tribunal is a reasonable and possible view. No substantial question of law. See CIT ALWAR VERSUS M/S SAKATA INX (INDIA) LTD [2017 (5) TMI 1586 - RAJASTHAN HIGH COURT]
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