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<h1>Substantial Questions Raised on ITAT's Transfer Pricing Decisions; Written Submissions Due in Three Weeks.</h1> <h3>M/s Thales Dis India Pvt Ltd (Earlier Known As Gemalto Digital Security Pvt Ltd Versus Asst Commissioner Of Income Tax Circle 25 (1) & Ors</h3> M/s Thales Dis India Pvt Ltd (Earlier Known As Gemalto Digital Security Pvt Ltd Versus Asst Commissioner Of Income Tax Circle 25 (1) & Ors - TMI Issues involved:The judgment addresses the following substantial questions of law:a) Whether the Income Tax Appellate Tribunal has erred in making a 5% adjustment as held by the CIT(A)Rs.b) Whether the ITAT was correct in ruling that the CIT(A) should have applied the Re-Sale Price Method instead of the internal CUP method for 8K CardsRs.c) Whether the ITAT was right in approving the method of benchmarking each product segment against comparable companies at the entity levelRs.d) Whether the ITAT erred in disregarding the alternative submissions made under Rule 27 of the ITAT Rules regarding the selection of comparablesRs.Details of the Judgment:1. The court, after hearing the counsels for both parties, identified the substantial questions of law related to the appeal.2. The respondents were given three weeks to file their Written Submissions on the record, specifying the pdf page numbers of the digital court record.3. The appeal was scheduled to be heard again on 01.05.2024 for further proceedings.