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2019 (9) TMI 880 - HC - Income TaxTransfer pricing adjustment in respect of the international transaction OR on the entire sales - HELD THAT:- Transfer Pricing adjustment has to be done only in respect of related party transactions and not on all transactions. See SANDVIK ASIA PVT. LTD., [2018 (5) TMI 262 - BOMBAY HIGH COURT] Exclude Genesys International Corp Ltd. from the set of comparable - HELD THAT:- M/s. Genesys is engaged in a different business and, therefore, not functionally similar. This finding of fact is not shown to be perverse in any manner by the Revenue. Risk adjustment - only grievance of the Revenue before the Tribunal was the appropriate grant of risk adjustment to determine the ALP is to be decided by the Adjudicating Authority - HELD THAT:- Impugned order of the Tribunal has accepted the grievance of the Revenue and restored the issue to the TPO/Assessing Officer with direction to examine the allowability of risk adjustment as claimed. In the above facts and circumstances, the question as proposed is pre-mature and does not give rise to any substantial question of law.
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