2026 (3) TMI 1482

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.... : Shri Dharm Veer Singh, CIT(DR) ORDER PER NAVEEN CHANDRA, ACCOUNTANT MEMBER:- This appeal by the Revenue is preferred against the order of the Ld. Commissioner of Income Tax (Appeals)-1, New Delhi [hereinafter referred to as the 'Ld. CIT(A)'], dated 10.08.2015 arising out the assessment order dated 20.03.2014 passed u/s 143(3) of the Income Tax Act, 1961(hereinafter referred to as the "....

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....AT order on account of non-consideration of ratio of the Hon'ble Supreme Court in M/s SG Asia Holding (India) Pvt. Ltd. in Civil Appeal No.6144 of 2009, order dated 30.08.2018. The ratio of the hon'ble Supreme Court was that where the international transaction was above Rs. 5 crores, same should have been referred to Id. TPO for determination of arm's length price of the international tran....