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2018 (7) TMI 52 - HC - Income TaxTPA - comparability of certain companies selected by the TPO and consequent adjustment made in respect of ALP of international transactions - substantial question of law or fact - Held that:- There may be cases where the Tribunal giving its own reasons and findings has found certain comparables to be good comparables to arrive at an ‘Arm’s Length Price’ in the case of the assessee with which the assessee may not be satisfied and have filed such appeals before this Court. Therefore we clarify that mere dissatisfaction with the findings of facts arrived at by the learned Tribunal is not at all a sufficient reason to invoke Section 260-A of the Act before this Court. The controversy involved herein is no more res integra in view of the decision of this Court in [2018 (6) TMI 1327 - KARNATAKA HIGH COURT], wherein it has been observed that unless the finding of the Tribunal is found ex facie perverse, the Appeal u/s. 260-A of the Act, is not maintainable.- Decided against revenue
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