https://www.taxtmi.com/caselaws?id=310278 The HC dismissed the Revenue's appeal, finding no substantial question of law regarding the ITAT's decision on ALP adjustments and profit margin for the Assessment Year 2004-05. The Tribunal ruled that transactions with an AE must be at arm's length from each other, and if one end is at ALP, the other must also be considered at arm's length. The Court noted that the TPO's determination of ALP was unjustified, as the TPO had accepted the transaction at ALP in the AE's hands. The appeal was dismissed, as it did not raise a substantial question of law. en-us Thu, 12 Jul 2018 00:00:00 +0530 Mon, 16 Oct 2023 18:55:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310278 The HC dismissed the Revenue's appeal, finding no substantial question of law regarding the ITAT's decision on ALP adjustments and profit margin for the Assessment Year 2004-05. The Tribunal ruled that transactions with an AE must be at arm's length from each other, and if one end is at ALP, the other must also be considered at arm's length. The Court noted that the TPO's determination of ALP was unjustified, as the TPO had accepted the transaction at ALP in the AE's hands. The appeal was dismissed, as it did not raise a substantial question of law. Case-Laws Income Tax Thu, 12 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310278