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TMI Blog2016 (5) TMI 454X X X X Extracts X X X X X X X X Extracts X X X X ..... ORDER P. C. 1. This appeal was on board on 12th April, 2016. At which time we passed the following order: 1. This Appeal filed by the Revenue raises questions with regard to whether transfer pricing adjustment consequent to arriving at Arm Length Price (ALP) is required to be done only in respect of international transactions or this adjustment is to be done in respect to all the business transactions of the Assessee i.e. at entity level. 2. A similar issue which was raised by the Revenue before this Court in Commissioner of Income Tax Vs. M/s. Tara Jewels Exports Pvt. Ltd. (Income Tax Appeal No.1814 of 2013) decided on 5th October, 2015, Commissioner of Income Tax Vs. Goldstar Jewellery Design (P.)Ltd. (2016) 67 taxmann ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nting out decisions in its favour in subsequent cases. This inspite of the fact when we have been informed in another context that a Commissioner (Judicial) has been appointed to oversee the litigation in Courts on behalf of the Revenue. It may be pointed out that the Revenue was represented by the same counsel in Global Jewellery Pvt. Ltd. (supra) and in M/s. Tara Jewels Exports Pvt. Ltd. (supra) i.e. the first in the three cases referred to above. Moreover the same counsel in M/s. Goldstar Jewellery Design (P.) Ltd. (supra) did not dispute that this issue is concluded against the Revenue by the decision in M/s. Tara Jewels Exports Pvt. Ltd. (supra). 4. Mr. Pinto, the learned counsel for the Revenue is unable to inform us whether M/s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... learned counsel appearing for the Revenue further states that all the orders referred to above arise from orders passed by different Commissionerates of Income Tax, therefore the officers were in no position to inform him of the order passed by this Court in Global Jewellery Pvt. Ltd. (supra) when he appeared in the other two appeals referred to above. We are unable to understand the above submission. Each Commissionerate is not a separate entity. All of them are a part of the Income Tax Department which as an entity is in appeal before us in all the above cases. We understand that Mumbai has a Chief Principal Commissioner of Income Tax at the helm of all the Chief Commissioners in Mumbai. Thus they must be having a system in place of keepi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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