PCIT v. Mentor Graphics (India) Pvt. Ltd. (2024)469 ITR 524 (Delhi)(HC)

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparable-No substantial question of law.[S.260A]

Dismissing the appeal of the Revenue the Court held that the appeal was confined to the direction issued by the Tribunal to exclude four comparables. Concerning the four comparables in issue, the Tribunal had returned findings of fact. No question of law arose from its order. (AY.2008-09)

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