https://www.taxtmi.com/caselaws?id=344813 The appeal challenging concurrent findings of the Commissioner of Income Tax (Appeals) and the Tribunal regarding international transactions with an associate enterprise was dismissed. The appellant's arguments on arm's length pricing, applicability of Section 92C(2), and the comparison of companies were not accepted. The Tribunal's evaluation of the appellant's operating margin within the arm's length range led to the dismissal of the appeal due to the absence of substantial questions of law. The appeal was dismissed without costs, emphasizing that new grounds not raised before lower authorities cannot be introduced in the appeal. en-us Wed, 07 Jun 2017 00:00:00 +0530 Tue, 01 Aug 2017 10:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=344813 The appeal challenging concurrent findings of the Commissioner of Income Tax (Appeals) and the Tribunal regarding international transactions with an associate enterprise was dismissed. The appellant's arguments on arm's length pricing, applicability of Section 92C(2), and the comparison of companies were not accepted. The Tribunal's evaluation of the appellant's operating margin within the arm's length range led to the dismissal of the appeal due to the absence of substantial questions of law. The appeal was dismissed without costs, emphasizing that new grounds not raised before lower authorities cannot be introduced in the appeal. Case-Laws Income Tax Wed, 07 Jun 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=344813