2016 (2) TMI 1083

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....This appeal under Section 260A of the Income Tax Act, 1961 ('Act') by the Revenue is against an order dated 26th May 2015 passed by the Income Tax Appellate Tribunal ('ITAT') in ITA No. 945/DEL/2015 for the Assessment Year ('AY') 2010-11. 2. Broadly three issues have been sought to be urged by the Revenue. 3. As far as the first issue concerning the transfer pricing adjustment is concerned, it i....

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....ular No. 5/2014 of the Central Board of Direct Taxes dated 11th February 2014. 5. Having heard learned counsel for the Revenue and considering the fact that the judgment in CIT v. Holcim India (P) Ltd. (supra) was delivered on 5th September 2014, the Court is not persuaded to accept the above plea of the learned counsel for the Revenue. In any event, the circular of CBDT cannot possibly override ....