https://www.taxtmi.com/caselaws?id=330079 Revenue's Section 260A appeal failed to raise any substantial question of law because the Tribunal's factual findings stood unchallenged: the transaction between the domestic entities was independently negotiated on its own terms, and the assessee's arm's length price determination was found reasonable. The Transfer Pricing Officer's method was not one of the methods prescribed under Section 92C, and the Tribunal's refusal to remand for recomputation on a different basis was also not disputed. Even if Revenue's reading of Section 92B were accepted, the issue would remain academic. The appeal was therefore not entertained and was dismissed, leaving the legal questions open for an appropriate case. en-us Mon, 11 Jul 2016 00:00:00 +0530 Thu, 09 Jul 2026 14:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=330079 Revenue's Section 260A appeal failed to raise any substantial question of law because the Tribunal's factual findings stood unchallenged: the transaction between the domestic entities was independently negotiated on its own terms, and the assessee's arm's length price determination was found reasonable. The Transfer Pricing Officer's method was not one of the methods prescribed under Section 92C, and the Tribunal's refusal to remand for recomputation on a different basis was also not disputed. Even if Revenue's reading of Section 92B were accepted, the issue would remain academic. The appeal was therefore not entertained and was dismissed, leaving the legal questions open for an appropriate case. Case-Laws Income Tax Mon, 11 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=330079