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2023 (5) TMI 1014 - SCH - Income TaxTP Adjustment - HELD THAT:- By passing the impugned judgment and order, the High Court has relied upon its earlier decision in the case of Principal Commissioner of Income Tax and Another vs. M/s Softbrands India Pvt. Ltd. [2018 (6) TMI 1327 - KARNATAKA HIGH COURT] As required to be noted that the decision of the Karnataka High Court in the case of Softbrands India Pvt. Ltd., (supra) fell for consideration before this Court in the recent decision of this Court in the case of SAP Labs India Private Limited [2023 (4) TMI 859 - SUPREME COURT] - Therefore, the matter is now required to be remitted back to the High Court to decide the Appeal afresh in accordance with law and on its own merits and in light of the observations made by this Court in the case of Sap Labs India Private Limited (supra). The impugned judgment and order passed by the High Court insofar as it relates to transfer pricing is hereby quashed and set aside. The matter is remanded back to the High Court to consider the issues/questions with respect to transfer pricing afresh in accordance with law and in light of the observations made by this Court in Sap Labs India Private Limited (supra)
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