2020 (6) TMI 838

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Kumar, Senior Standing Counsel assisted by Ms.K.G.Usha Rani, Junior Standing Counsel For the Respondent: Mr.R.Vijayaraghavan, For M/s.Subbaraya Aiyar, Padmanabhan & Ramamani Judgment was delivered by T.S.Sivagnanam,J. We have heard Mr.T.R.Senthil Kumar, learned Senior Standing Counsel assisted by Ms.K.G.Usha Rani, learned Junior Standing Counsel appearing for the appellant-Revenue and Mr.....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e ALP? 2. Whether under the facts and circumstances of the case, the Income Tax Appellate Tribunal is right in holding that the transactions of the assessee with its AE are at arms length? 3. Whether based on material available before it, the Tribunal could have arrived at conclusion that the transactions of the assessee with its AE are at arms length?" 4. The learned Senior S....