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The High Court upheld the Income Tax Appellate Tribunal's (ITAT) decision regarding the applicability of Section 92(3) in determining the arm's length price for intra-group services. The ITAT correctly held that if the arm's length price is determined separately for multiple categories of international transactions, any transfer pricing adjustment for one transaction would necessitate an adjustment to the second category, resulting in reduced profits. The High Court found no legal grounds to challenge the ITAT's ruling, as accepting the appellant's contention would reduce the taxable income. Consequently, the appeal was dismissed as it failed to raise any substantial question of law.
The High Court upheld the Income Tax Appellate Tribunal's (ITAT) decision regarding the applicability of Section 92(3) in determining the arm's length price for intra-group services. The ITAT correctly held that if the arm's length price is determined separately for multiple categories of international transactions, any transfer pricing adjustment for one transaction would necessitate an adjustment to the second category, resulting in reduced profits. The High Court found no legal grounds to challenge the ITAT's ruling, as accepting the appellant's contention would reduce the taxable income. Consequently, the appeal was dismissed as it failed to raise any substantial question of law.
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