TP: Appropriateness of one or other method cannot be gone into Section 260A appeal

PCIT Vs. Gulbrandsen Chemicals Pvt. Ltd. (Gujarat High Court) The Tribunal has taken into consideration the voluminous documentary evidence on record for the purpose of coming to the conclusion of adoption of TNMM by the assessee as the Most Appropriate Method of arriving at ALP. The Delhi High Court in the case of Make My Trip India (P.) Ltd. (supra) has also held that difference of opinion as to the appropriateness of one or the other method cannot be gone into in the appeal under Section 260A of the Act, 1961 by observing as under: “5. The Court is of the opinion that no substantial quest...