Held, dismissing the appeal the appeal, the court had not refused to scrutinise the Tribunal’s findings on the arm’s length price. The court had considered the matter on the merits and came to the conclusion that no substantial questions of law arose. The order passed in the appeal was in conformity with the directions of the Supreme Court. Followed, PCIT v. PTC Software (I) (P) Ltd (2019) 101 taxmann.com 117 (Bom)(HC)
PCIT v. John Deere India Pvt. Ltd. (2024)467 ITR 127 (Bom)(HC)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Order in conformity with directions of Supreme Court guidelines-No substantial question of law.[S. 260A]