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2015 (4) TMI 1107 - BOMBAY HIGH COURT

2015 (4) TMI 1107 - BOMBAY HIGH COURT - TMI - Transfer pricing adjustments - Held that:- Appeal admitted on the following three substantial questions of law :

(1) Whether on the facts and circumstances of the case and in law, the Hon'ble ITAT is justified in holding that the Transfer Pricing Officer ought to have confined himself to transfer pricing adjustments to the international AE transactions only, instead at entity level, without appreciating that the assessee had not furnished .....

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nd therefore, if the overall margins are less than arm's length margins, the short fall must be on account of AE transactions only and not on pro rata basis ?

(3) Whether on the facts and circumstances of the case and in law, the Hon'ble ITAT is justified in deleting the addition of ₹ 1,29,55,813/- holding that the adjustment is within +/- 5% as the ITAT has wrongly worked out adjustment on sales, whereas the TPO had benchmarked the purchase transactions and had worked out the a .....

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substantial questions of law : (1) Whether on the facts and circumstances of the case and in law, the Hon'ble ITAT is justified in holding that the Transfer Pricing Officer ought to have confined himself to transfer pricing adjustments to the international AE transactions only, instead at entity level, without appreciating that the assessee had not furnished segmental audited accounts before the Transfer Pricing Officer ? (2) Whether on the facts and circumstances of the case and in law, th .....

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