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2018 (8) TMI 2104 - HC - Income TaxTP Adjustment - mirror transactions ALP adjustments - Tribunal held that in mirror transactions ALP adjustments cannot be done, i.e., if one transaction is treated as at Arm’s Length, no adjustment can be made on the other related corresponding transaction of the AE without appreciating that this stand is against the provisions of Section 92(3) of the Act?” - substantial question of law - HELD THAT:- As this Court in a recent judgment in 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 appellant, the appeal at the instance of an assessee or the Revenue under Section 260-A of the Act is not maintainable. No substantial question of law arises in the present case
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