2016 (5) TMI 1434

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..... ns qua any of the comparables or the conclusion of the ITAT thereon is perverse. The Court does not find the said issue giving rise to any substantial question of law. Foreign exchange fluctuation loss being considered as part of the operative expenses, the issue stands covered against the Revenue and in favour of the Assessee by the decision of the Supreme Court in Commissioner of Income-tax v .....

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..... AT by the impugned order allowed the appeal of the Assessee on the question of the correctness of the additions made by the Transfer Pricing Officer (TPO) by way of adjustment of Arms Length Price (ALP) assessing the total income of the Assessee at ₹ 112.39 crores as against total income of ₹ 98.75 crores declared by the Assessee. In effect, the ITAT has accepted the case of the Assess .....

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..... cision of the Supreme Court in Commissioner of Income-tax v. Woodward Governor India (P) Ltd. (2009) 312 ITR 254 (SC). Likewise, the issue concerning the rate of interest for capital adjustment is covered against the Revenue and in favour of the Assessee in terms of the decision of this Court in Cotton Natural (P) Ltd. v. CIT (2015) 276 CTR 445. Consequently, no substantial question of law arises .....

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