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2018 (8) TMI 2094 - KARNATAKA HIGH COURTTP Adjustment - substantial questions of law raised before the High Court u/s 260-A - substantial quantum of international trade and transactions depends upon the fair and quick judicial dispensation in such cases - extra credit allowed can be considered as an independent international transaction and the same be compared with the internal CUP being average cost of the total funds available to the assessee, directed the TPO to find out the cost of the total funds available to the assessee and same should be adopted as internal CUP for benchmarking of this independent international transaction i.e. allowing extra credit in addition the agreed credit period of 30 days - HELD THAT:- This Court in a recent judgment in cit Vs. M/s. 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 appellants, the appeal at the instance of an assessee or the Revenue u/s 260-A of the Act is not maintainable.
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