2024 (11) TMI 1164 - SCH - Income Tax

Transfer pricing adjustment - international transaction between WOIL and its AE involving the AMP expenses within the meaning of Section 92B or not? - As decided by HC 2015 (12) TMI 1188 - DELHI HIGH COURT Revenue has been unable to demonstrate by some tangible material that there is an international transaction involving AMP expenses between WOIL and Whirlpool USA. In the absence of that first step, the question of determining the ALP of such a transaction does not arise. HELD THAT - We are not inclined to entertain the Special Leave Petitions under Article 136 of the Constitution of India. Special Leave Petitions are accordingly dismissed.