2017 (11) TMI 807

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..... een the assessee and the Revenue authorities or amongst the Revenue authorities in the application of one or other methods for determining ALP ipso facto does not constitute question of law. This, however, not to say that if in a given case the aggrieved party is able to show that the rule applied has led to distortion or prejudice as the case may be, the question of law does not arise. In the pre .....

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..... appropriateness of the Resale Price Method (RPM), which was accepted by the assessee. The TPO, however, rejected that and applied the Transactional Net Margin Method (TNMM) as the most appropriate and proximate test. The CIT(A), however, felt otherwise and reversed the findings of the AO. Those findings were endorsed and affirmed by the ITAT in the impugned order. 2. This Court is of the opinio .....

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