2023 (7) TMI 181 - SCH - Income Tax

TP adjustment u/s 92C - ALP determination - international transactions relating to receipts in respect of investment advisory services - order passed by this Court in the case of M/s. SAP Labs India (P) Ltd. v. CIT 2023 (4) TMI 859 - SUPREME COURT wherein this Court has set aside similar orders and remanded the matter to the High Court for fresh consideration. In that view without expressing any opinion on merits the order impugned herein is set aside. The appeal is restored to the file of the High Court of Judicature at Bombay to re-hear on all aspects as indicated in the above referred judgment.

Summary

The Supreme Court set aside the impugned order and remanded the matter to the High Court for fresh consideration based on a previous case ruling. The appeal is restored to the High Court for re-hearing. Special Leave Petition and pending applications are disposed of.