2024 (12) TMI 993 - SCH - Income Tax

TP Adjustment - MAM selection - RPM v/s TNMM - Tribunal rejecting the Transactional Net Margin Method (TNMM) as used by TPO in ascertaining ALP - Delay filling SLP - As decided by HC 2023 (11) TMI 289 - DELHI HIGH COURT once the ITAT, on considering the relevant facts as well as the order of the TPO, had concluded that the business of the assessee was merely that of a pure trader, and there was no value addition made before re-selling the particular products (i.e. the SIM cards), its consequent finding that RPM is the Most Appropriate Method, is irreproachable. HELD THAT - There is a delay of 311 days in filing the Special Leave Petition which has not been satisfactorily explained. Even otherwise, we have gone through the Special Leave Petition and do not find any merit in the same. Special Leave Petition is, therefore, dismissed on the ground of delay as well as on merits.

Summary

The Supreme Court dismissed the Special Leave Petition due to a delay of 311 days and lack of merit. Pending applications were disposed of. (TMI citation)