2015 (11) TMI 1628

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.... appeal under Section 260A of the Income Tax Act (the Act) filed by the Revenue challenges the order dated 18th January, 2013 passed by the Income Tax Appellate Tribunal (the Tribunal). The impugned order pertains to the Assessment Year 200809. 2. The Revenue has urged the following questions of law for our consideration. "(i) Whether on the facts and in law, the Tribunal was justified in rejec....

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....y the AE transactions without appreciating that (a) the assessee itself in its transfer pricing study report (TPSR) has chosen entity level PLI to benchmark the AE transactions (b) the assessee had itself failed to furnish audited segmental accounts and therefore, the TPO had rightly applied revised PLI at the entity level to determine the ALP?" 3. So far as the question no. (iii) is concerned, C....