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The Commissioner of Income Tax – 8 Versus Global Jewellery Pvt. Ltd.

2015 (4) TMI 1107 - BOMBAY HIGH COURT

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 .....

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r Pricing Officer ?

(2) Whether on the facts and circumstances of the case and in law, the Hon'ble ITAT is justified in restricting the adjustment only on international transactions without appreciating that (a) the assessee had applied TN .....

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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 & .....

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transactions being not at arm's length, the assessee has got away without any adjustment.?” - INCOME TAX APPEAL NO. 1395 OF 2013 - Dated:- 16-4-2015 - S.C. DHARMADHIKARI & A.K. MENON, JJ. Mr. Arvind Pinto for the Appellant Mr. for the Respondent .....

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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 e .....

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the adjustment only on international transactions without appreciating that (a) the assessee had applied TNMM at entity level to justify its controlled transactions on the basis of overall margins and (b) the presumption underlying arm's length .....

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e 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 .....

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