TMI Blog2018 (7) TMI 2101X X X X Extracts X X X X X X X X Extracts X X X X ..... and findings has found certain comparables to be good comparables to arrive at an 'Arm's Length Price' in the case of the assessees with ' which the assessees may not be satisfied and have filed such appeals before this Court. Therefore we clarify that mere dissatisfaction with the findings of facts arrived at by the learned Tribunal is not at all a sufficient reason to invoke Section 260-A of the Act before this Court - We are of the considered opinion that no substantial question of law arises for consideration in the present case. - I.T.A.No.104/2015 - - - Dated:- 16-7-2018 - Dr. Vineet Kothari And Mrs S.Sujatha, JJ. Mr. K.V.Aravind, Adv. for Appellants Revenue. Mr. Ankur Pai.. Adv. for Mr. K.R.Vasudevan, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ant portion of the order for easy reference: XXXXXXX Respectfully following the decision of the co-ordinate Bench of this Tribunal, we nemand the issue also to the file of the AO/TPO for re- determination of the rcyalty as per directions of the Tribunal for the assessment year 2007-08. 4. The controversy involved herein is no more res integra in view of the decision of this Court in I.T.A. Nos.536/2015 537/2015 dated 25.06.2018 [Pri. Commissioner of Income Tax Anr. V/ s. M/s.Softbrands India Pvt. Ltd.,], wherein it has been observed that unless the finding of the Tribunal is found ex facie perverse, the Appeal u/ s. 260-A of the Act, is not maintainable. The relevant portion of the Judgment is quoted below for ready referen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and parameters will have to be applied, even if such appeals are filed by the Assessees, because, there may be cases where the TFbunal giving its own reasons and findings has found certain comparables to be good comparables to arrive at an 'Arm's Length Price' in the case of the assessees with ' which the assessees may not be satisfied and have filed such appeals before this Court. Therefore we clarify that mere dissatisfaction with the findings of facts arrived at by the learned Tribunal is not at all a sufficient reason to invoke Section 260-A of the Act before this Court. 58. The appeals filed by the Revenue are therefore dismissed with no order as to costs. 5. In the circumstances, having heard the learned Cou ..... X X X X Extracts X X X X X X X X Extracts X X X X
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