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TP disputes on Comparables & Filter selection are not substantial question of law
Case Law Details
- Case Name
- Pr. CIT Vs M/s Softbrands India P. Ltd. (Karnataka High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2006-07
- Courts
- All High Courts, Karnataka High Court
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Pr. CIT Vs M/s. Softbrands India P. Ltd. (Karnataka High Court)
Facts of the case:
The assessee was engaged in providing software services to its associated enterprise (AE). During the assessment year, it earned an operating profit of 8.33% on cost. The assessee applied Comparable Uncontrolled Price (CUP) method for substantiating arm’s length price (ALP) of its international transactions.
Transfer Pricing officer (TPO) rejected CUP method and applied Transactional Net Margin Method (TNMM). The TPO used a set of 20 comparables and determined ALP at cost plus 20.68%, which a...
