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| The Tax Publishers2019 TaxPub(DT) 4737 (Karn-HC) : (2019) 414 ITR 0662 INCOME TAX ACT, 1961
Section 260A
Tribunal giving its own reasons and findings had found certain companies to be not good comparables to arrive at ALP and mere dissatisfaction with findings of facts arrived at by Tribunal could not be at all a sufficient reason to invoke section 260A.
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Appeal (High Court) - Maintainability - No substantial question of law -
Revenue by way of appeal filed under section 260A challenged exclusion of certain comparables by Tribunal to benchmark international transaction entered undertaken by assessee. Held: Tribunal giving its own reasons and findings had found certain companies to be not good comparables to arrive at ALP and mere dissatisfaction with findings of facts arrived at by Tribunal could not be at all a sufficient reason to invoke section 260A. Appeal was, therefore, dismissed.
Followed(Pr. CIT v. Softbrands India (P) Ltd. (2018) 406 ITR 513 (Karn))
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
IN THE KARNATAKA HIGH COURT
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