https://www.taxtmi.com/caselaws?id=304359 The High Court emphasized the need for ex-facie perversity in the Income Tax Appellate Tribunal's findings to maintain an appeal under Section 260A. It clarified that issues related to comparables and filters do not generally constitute substantial questions of law. The Court held that extra credit beyond the agreed period should be separately benchmarked to prevent profit shifting. It directed the Assessing Officer to determine the interest rate for benchmarking extra credit. Appeals under Section 260A must involve significant legal interpretations, not just dissatisfaction with factual findings. The Court dismissed the Revenue's appeal, stressing the importance of substantial legal issues in appeals. en-us Fri, 31 Aug 2018 00:00:00 +0530 Mon, 11 May 2026 10:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=304359 The High Court emphasized the need for ex-facie perversity in the Income Tax Appellate Tribunal's findings to maintain an appeal under Section 260A. It clarified that issues related to comparables and filters do not generally constitute substantial questions of law. The Court held that extra credit beyond the agreed period should be separately benchmarked to prevent profit shifting. It directed the Assessing Officer to determine the interest rate for benchmarking extra credit. Appeals under Section 260A must involve significant legal interpretations, not just dissatisfaction with factual findings. The Court dismissed the Revenue's appeal, stressing the importance of substantial legal issues in appeals. Case-Laws Income Tax Fri, 31 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=304359