TMI Blog2018 (7) TMI 379X X X X Extracts X X X X X X X X Extracts X X X X ..... t is not maintainable - No substantial question of law - Appeal dismissed. - I.T.A.No.294/2016 - - - Dated:- 28-6-2018 - Dr. Vineet Kothari And Mrs. S. Sujatha, J.J. Mr. Sanmathi. E. I, Advocate- For the Appellant Ms. Lakshmy Iyengar, Adv. for R2; R1 Served- For the Respondent JUDGMENT 1. The Appellants - Revenue have filed this appeal raising purported substantial questions of law arising from the Order of the learned Income Tax Appellate Tribunal Bench B , Bangalore, Annexure A dated 30/09/2015 in IT(TP)A.No.436/Bang/2015 for AY 2010-11. 2. The appellants - Revenue have suggested one substantial question of law which is quoted below for ready reference: - Whether on the facts and in the circumstances of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... road and sale thereof in the local market. DRP had remitted the matter back to the AO for evaluating the value of international transactions of the assesse based on RPM. However, in the assessment order passed, AO had simply deleted the additions suggested by the TPO. Since the fact-situation is very similar to that in the assessment year 2008-09, in our opinion the directions given by this Tribunal for the said year would apply here also. Relevant paragraphs 11 to 21 of the order dt.17.10.2014, is reproduced hereunder: For the impugned assessment year also therefore we set aside the order of lower authorities and remit the issue of fixation of ALP of the international transactions entered by the assessee, back to the file of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the comparables have been rightly picked up or not, Filters for arriving at the correct list of comparables have been rightly applied or not, do not in our considered opinion, give rise to any substantial question of law. 56. We are therefore of the considered opinion that the present appeals filed by the Revenue do not give rise to any substantial question of law and the suggested substantial questions of law do not meet the requirements of Section 260-A of the Act and thus the appeals filed by the Revenue are found to be devoid of merit and the same are liable to be dismissed. 57. We make it clear that the same yardsticks and parameters will have to be applied, even if such appeals are filed by the Assessees, because, there ma ..... X X X X Extracts X X X X X X X X Extracts X X X X
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