https://www.taxtmi.com/caselaws?id=464881 HC dismissed the Revenue's appeal on transfer pricing adjustment, holding that no substantial question of law arose under s.260A. The Revenue sought to challenge the ITAT's grant of risk adjustment under Rule 10B(e)(iii), contending that such adjustment was impermissible and that the ITAT's arm's length price determination was perverse. HC noted that this contention had not been raised before the ITAT and, relying on precedent, held that it could not entertain a question first urged at the appellate stage. Consequently, the challenge to the TP adjustment and arm's length price determination was rejected. en-us Wed, 12 Jul 2023 00:00:00 +0530 Wed, 19 Nov 2025 10:50:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464881 HC dismissed the Revenue's appeal on transfer pricing adjustment, holding that no substantial question of law arose under s.260A. The Revenue sought to challenge the ITAT's grant of risk adjustment under Rule 10B(e)(iii), contending that such adjustment was impermissible and that the ITAT's arm's length price determination was perverse. HC noted that this contention had not been raised before the ITAT and, relying on precedent, held that it could not entertain a question first urged at the appellate stage. Consequently, the challenge to the TP adjustment and arm's length price determination was rejected. Case-Laws Income Tax Wed, 12 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464881