When the matter came up for hearing the Hon\u2019ble Court observed that in few of the matters the appeal of the revenue on the above issue were dismissed after considering the detailed arguments of the assessee and the revenue. The said orders of the Bombay High Court were also accepted by the revenue. The Hon\u2019ble court also observed that similar matter was decided in favour of the assessee by the Delhi High Court. However, in one of the matter the issue was admitted by the Bombay High Court by an exparte order which was not brought to the notice of the Hon\u2019ble High Court. To avoid such an inconsistent stand of the revenue, the Hon\u2019ble Court directed the Principal Chief Commissioner to stream line the procedure to be followed for filing an appeal to the High Court and to bring transparency. In pursuance to the said direction of the Hon\u2019ble High Court, Principal Chief Commissioner of Income tax filed an affidavit before the Court on 5\/5\/2016, wherein he has informed that he has constituted the committee of Chief Commissioners on 3\/5\/2016 (Refer copy enclosed). Principal Chief Commissioner in his affidavit stated that web site www.incometaxgovin it has been decided to add a legal corner on the web site where all questions of law admitted, dismissed by the Hon\u2019ble Bombay High Court will be hosted. The access to the web site will be provided to all concerned for easy reference where the questions of law would be bunched section wise. Expert committee will meet every week and decision pronounced by the Bombay High Court will be discussed and appropriate action will be taken (Refer Affidavit). Hon\u2019ble High Court also agreed with the suggestion of Dr. K. Shivaram, Sr. Advocate that the legal corner on the web site should also indicate whether the question of law formulated by the Revenue was rejected and the same has been accepted by the Income tax Dept. The counsel for the revenue stated that on instruction from the Principal Chief Commissioner the web site will be functional by 15\/6\/2016. <\/p>\n","protected":false},"excerpt":{"rendered":"
This appeal filed by the Revenue raises questions with regard to whether transfer pricing adjustment consequent to arriving at Arms Length Price (ALP) is required to be done only in respect of the international transactions or this adjustment is to be done in respect of all the business transactions of the assessee i.e. at the entity level. This Appeal was on board and detailed orders were passed indicating that the Revenue has not been bringing to the notice of the Court orders of admission in its favour in the subsequent Appeals filed by it an identical questions. This has resulted in the subsequent appeals filed by the Revenue raising identical questions being dismissed at the stage of admission after having heard the parties at some length<\/p>\n