Transfer pricing dispute over internal CUP, resale price method and Rule 27 submissions; appeal admitted for further hearing.

The appeal concerned transfer pricing issues, including exclusion of internal CUP in favour of the resale price method for 8K Cards, benchmarking at entity level, and whether alternative submissions under Rule 27 of the Income-tax Appellate Tribunal Rules, 1963 were not considered. Notice was issued and the appeal was admitted. The court directed filing of written submissions and listed the matter for further hearing.

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Issues: Whether the appeal raised substantial questions concerning the transfer pricing adjustment, the exclusion of internal CUP in favour of the resale price method for 8K Cards, benchmarking at entity level, and the alleged non-consideration of alternative submissions under Rule 27 of the Income-tax Appellate Tribunal Rules, 1963.

Outcome: Notice issued and the appeal admitted; written submissions were directed to be filed and the matter was listed for further hearing.

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