https://www.taxtmi.com/caselaws?id=350928 The High Court dismissed the appeal as it found no legal basis to consider the questions raised by the Revenue regarding the appropriateness of the Resale Price Method (RPM) versus the Transactional Net Margin Method (TNMM) for determining the Arm's Length Price (ALP) and the classification of seed development/agronomy expenditure as capital in nature. The Court emphasized that unless distortion or prejudice is demonstrated, a question of law does not arise, and in this case, no such factors were present. The Court also noted that the Transfer Pricing Officer (TPO) endorsed the RPM in a subsequent year, further supporting the dismissal of the appeal on these issues. en-us Mon, 13 Nov 2017 00:00:00 +0530 Wed, 15 Nov 2017 10:02:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=350928 The High Court dismissed the appeal as it found no legal basis to consider the questions raised by the Revenue regarding the appropriateness of the Resale Price Method (RPM) versus the Transactional Net Margin Method (TNMM) for determining the Arm's Length Price (ALP) and the classification of seed development/agronomy expenditure as capital in nature. The Court emphasized that unless distortion or prejudice is demonstrated, a question of law does not arise, and in this case, no such factors were present. The Court also noted that the Transfer Pricing Officer (TPO) endorsed the RPM in a subsequent year, further supporting the dismissal of the appeal on these issues. Case-Laws Income Tax Mon, 13 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=350928