Held that the Tribunal had returned findings of fact as to why it had rejected the three comparables. The findings were not perverse and, therefore, the order of the Tribunal need not be interfered with. On account of interest received on receivables and had restored the issue to the Assessing Officer for verifying the assessee’s claim, keeping in view its own decision for the assessment year 2015-16 after providing reasonable opportunity of hearing to the assessee. Order of Tribunal is affirmed. (AY.2014-15)
PCIT v. Qualcomm India Pvt. Ltd. (2023)459 ITR 9 /156 taxmann.com 288 (Delhi)(HC)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Rejection of comparables based on findings of fact in respect of functional dissimilarities-Interest on receivables-Working capital-Remanding the matter to Assessing Officer-Order of Tribunal is affirmed. [S. 260A]