TMI Blog2018 (8) TMI 2061X X X X Extracts X X X X X X X X Extracts X X X X ..... the Revenue under Section 260-A of the Act is not maintainable. No substantial question of law arises in the present case also - I.T.A. No. 358/2016 - - - Dated:- 1-8-2018 - THE HON'BLE DR. JUSTICE VINEET KOTHARI AND THE HON BLE MRS. JUSTICE S.SUJATHA For the Appellant : Mr. K.V. ARAVIND, ADV. For the Respondent : Mr. SANDEEP HUILGOL, ADV., FOR Mr. T. SURYANARAYANA, ADV. JUDGMENT 1. The Appellants-Revenue have filed this appeal u/s.260A of the Income Tax Act, 1961, raising purportedly one substantial question of law arising from the order of the ITAT, Bangalore Bench B , Bangalore, dated 18.11.2015 passed in IT(TP)A No.757/Bang/2011 (M/s.Avnet India Pvt. Ltd., vs. The Deputy Commissioner of Income-tax ) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... integral part of transaction of sale made to the AE and therefore, it has to be considered alongwith the main transaction. The similar issue had come up for consideration before the Co-ordinate Bench of Mumbai in the case of M/s Goldstar Jewellary Ltd. (Supra), wherein it was observed as under: xxxxxxxxxxxxxxx Respectfully following the above decision, we hold that there can be no separate international transaction of interest in the international transaction of sale. Early or late realization of sale proceeds is only incidental to transaction of sale, but not a separate transaction in nature. Since we hold that the impugned transaction of interest on delayed realization of sale proceeds is not international transaction, it is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the other hand, the appeals of the present tenor as to whether 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, ev ..... X X X X Extracts X X X X X X X X Extracts X X X X
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