https://www.taxtmi.com/caselaws?id=398655 The High Court upheld the Transfer Pricing Officer's determination of royalty rates, resulting in a disallowance of Rs. 86.88 crores. The court noted discrepancies in the TPO's approach for different assessment years, emphasizing the lack of a standard procedure. The dismissal of the writ petition was based on the appellant's failure to exhaust available remedies before approaching the High Court. The court reiterated that the High Court's jurisdiction under Article 226 is discretionary and should not be invoked if alternative remedies exist. The appellant was directed to approach the ITAT within four weeks, with all issues open for adjudication before the Tribunal. en-us Wed, 16 Sep 2020 00:00:00 +0530 Wed, 07 Apr 2021 14:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=398655 The High Court upheld the Transfer Pricing Officer's determination of royalty rates, resulting in a disallowance of Rs. 86.88 crores. The court noted discrepancies in the TPO's approach for different assessment years, emphasizing the lack of a standard procedure. The dismissal of the writ petition was based on the appellant's failure to exhaust available remedies before approaching the High Court. The court reiterated that the High Court's jurisdiction under Article 226 is discretionary and should not be invoked if alternative remedies exist. The appellant was directed to approach the ITAT within four weeks, with all issues open for adjudication before the Tribunal. Case-Laws Income Tax Wed, 16 Sep 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=398655