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2018 (8) TMI 1807 - HC - Income TaxTP Adjustment - Tribunal directing the AO/TPO to confine arm's length adjustment to the value of international transactions in the manufacturing segment of the asses see - TPO chosen TNMM method as the most appropriate method for determination of arm's length - Working capital adjustment - HELD THAT:- This court in a recent judgment in Principal CIT v. Softbrands India Pvt. Ltd. [2018 (6) TMI 1327 - KARNATAKA HIGH COURT] has held that in these type of cases, unless an ex facie perversity in the findings of the learned Income-tax Appellate Tribunal is established by the appellant, the appeal at the instance of an assessee or the Revenue under section 260A of the Act is not maintainable .No substantial question of law - Decided against revenue
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