Difference of opinion between CIT(A) & TPO cannot per se be a ground for interference

Pr. CIT Vs Makemy Trip India Pvt. Ltd. (Delhi High Court)

The Court is of the opinion that no substantial question of law arises. The difference of opinion between the CIT(A) and the TPO, as to the appropriateness of one or the other methods, cannot per se be a ground for interference; the appropriateness of the method unless shown to be contrary to the Rules specially Rules 10B and 10C, in the opinion of the Court, are hardly issues that ought to be gone into under Section 260A of the Income Tax Act.

Full Text of the High Court Judgment / Order is as follows:-

1. The question of law urged is whether the Tribunal in affirming the Appellate Commissioner’s Ruling with respect to the applicability of Transaction Net Margin Method (TNMM) was, in the circumstances of the case, erroneous.

2. The assessee is in the travel and tourism business. It provides on-line solutions for travel product and other comprehensive services for the global traveller including air tickets, hotel reservations, car bookings and holidays.

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