Transfer Pricing – If more than one price is determined by the most appropriate method, the ALP has to be the arithmetical mean of such prices

HIGH COURT OF DELHI Commissioner of Income-tax versus Mentor Graphics ( Noida) (P.) Ltd. BADAR DURREZ AHMED AND R.V.EASWAR, JJ. IT Appeal No. 1114 of 2008 APRIL 4, 2013 Ms. Suruchii Aggarwal for the Appellant. M.S. Syali, Ms. Husnal Syali and Mayank Nagi for the Respondent. JUDGMENT Badar Durrez Ahmed, J. In this appeal, the revenue has challenged the order of the Income Tax Appellate Tribunal, dated 02.11.2007, passed in ITA No. 1969/Del/2006, relating to the assessment year 2002-03. By virtue of an order dated 13.01.2011, a Division Bench of this court, while admitting the...