Transfer Pricing Cases can be taken up by High Court when it can be proved that a matter of fact gives rise to a question of law.

Transfer Pricing Cases can be taken up by High Court when it can be proved that a matter of fact gives rise to a question of law. https://www.taxtmi.com/article/detailed?id=11375 High Court jurisdiction over transfer pricing disputes arises when an issue of fact produces a substantial question of law, permitting scrutiny where the Tribunal's arm's length price determination departs from the Act and Rules, particularly Rules 10A-10E; perversity must be pleaded and supported by material. Questions of law include whether a transaction is an international transaction or whether enterprises are associated enterprises, whereas comparability, filter selection and benchmarking remain factual matters. en-us Wed, 03 May 2023 10:19:18 +0530 Wed, 03 May 2023 10:19:18 +0530 TaxTMI RSS Generator Transfer Pricing Cases can be taken up by High Court when it can be proved that a matter of fact gives rise to a question of law. https://www.taxtmi.com/article/detailed?id=11375 High Court jurisdiction over transfer pricing disputes arises when an issue of fact produces a substantial question of law, permitting scrutiny where the Tribunal's arm's length price determination departs from the Act and Rules, particularly Rules 10A-10E; perversity must be pleaded and supported by material. Questions of law include whether a transaction is an international transaction or whether enterprises are associated enterprises, whereas comparability, filter selection and benchmarking remain factual matters. Articles Income Tax Wed, 03 May 2023 10:19:18 +0530 https://www.taxtmi.com/article/detailed?id=11375