2023 (10) TMI 215 - SCH - Income Tax

TP adjustment - benchmarking international transactions of sale of Valves - aggregation of its transactions with the A.E. vs aggregation of its transactions with Non AE - HC confirmed 2019 (5) TMI 694 - BOMBAY HIGH COURT Tribunal order upholding the order of CIT (A) benchmarking international transactions of sale of Valves to its Associated Enterprise (AE) by aggregating all its transactions with the A.E. and comparing it with aggregation of all comparable Non AE transactions and deleting the TPA on export of Valves and Valves in Kit form to its AE in USA viz. Flow Serve Sulphur Spring (Flow Serve) by holding the benchmarking of international transactions by comparing controlled (AE) transactions with uncontrolled (NonAE) transactions HELD THAT - This Court is of the opinion that the impugned order does not call for interference. The special leave petition is accordingly dismissed. All pending applications are disposed of.

Summary

The Supreme Court dismissed the special leave petition as it found no reason to interfere with the impugned order. All pending applications were disposed of.