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2023 (7) TMI 808 - HC - Income TaxTP Adjustment - selection of MAM - TNMM OR Berry ratio - international transactions concerning indenting-transactions concerning the respondent/assessee and its AEs - Tribunal passed an order [2018 (10) TMI 1785 - ITAT DELHI] whereby it concluded that the Transaction Net Margin Method (TNMM) was the most suitable method - HELD THAT:- We are closing the instant appeals in view of the fact that the appellant/revenue chose not prefer an appeal against the order [2018 (10) TMI 1785 - ITAT DELHI] passed by the Tribunal in the AYs referred to hereinabove. According to us, the issues in the above-captioned appeals are pari materia with those that arose in AY 2007-08 to AY 2010-11. Via the impugned order, the Tribunal has, in sum, sought to re-examine the issue, in the light of the directions contained therein. The above-captioned appeals are, accordingly, closed as no substantial question arises for our consideration.
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