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TMI Blog2016 (5) TMI 1449X X X X Extracts X X X X X X X X Extracts X X X X ..... ed by the Revenue raises questions with regard to whether transfer pricing adjustment consequent to arriving at Arms Length Price(ALP) is required to be done only in respect of the international transactions or this adjustment is to be done in respect of all the business transactions of the assessee i.e. at the entity level. 2. On 12th April, 2016 and 18th April, 2016 this Appeal was on board and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he head of all the Commissionerates at Mumbai was directed to file affidavit indicating the steps being taken to ensure that a consistent view is taken by the Department. The two Commissioner's of Income Tax who had briefed counsel in the two appeals wherein identical questions were raised as in an earlier appeal and were dismissed as the Revenue had not pointed out to the Court that in an ear ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nstructions, states that it would possibly become functional by 15th June, 2016. We would want some certainty with regard to the date when the system would come into force. Further till such time as the website is updated to become functional, the method proposed to be adopted by the Income Tax Department to ensure that a inconsistent stand is not taken by the Revenue in different matters. In that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er in which it could be implemented. To us it appears that if these suggestions are implemented, we could have transparency and consistency in the stand taken by the Revenue. 10. We direct the Principal Chief Commissioner of Income Tax to file an affidavit on or before 13th June, 2016 and a copy of the affidavit may also be served upon Dr. Shivram, the learned counsel appearing for the Respondent ..... X X X X Extracts X X X X X X X X Extracts X X X X
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