https://www.taxtmi.com/caselaws?id=190936 The Court upheld the Tribunal's decision to dismiss the revenue's appeals regarding assessment years 2005-06 and 2006-07, focusing on the deletion of addition related to Arm's length price adjustment. The Court found that the Transfer Pricing Officer had not adequately considered the comparability of instances provided by the assessee, leading to non-compliance with natural justice principles. The Tribunal's scrutiny, supported by the Commissioner, affirmed the comparability of instances, resulting in the dismissal of the appeals. The Court emphasized the importance of substantiating claims of unfair treatment with material evidence and criticized frivolous complaints, ultimately dismissing the appeals with costs. en-us Fri, 22 Aug 2014 00:00:00 +0530 Thu, 09 Mar 2017 21:53:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=190936 The Court upheld the Tribunal's decision to dismiss the revenue's appeals regarding assessment years 2005-06 and 2006-07, focusing on the deletion of addition related to Arm's length price adjustment. The Court found that the Transfer Pricing Officer had not adequately considered the comparability of instances provided by the assessee, leading to non-compliance with natural justice principles. The Tribunal's scrutiny, supported by the Commissioner, affirmed the comparability of instances, resulting in the dismissal of the appeals. The Court emphasized the importance of substantiating claims of unfair treatment with material evidence and criticized frivolous complaints, ultimately dismissing the appeals with costs. Case-Laws Income Tax Fri, 22 Aug 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=190936