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TMI Blog2024 (9) TMI 1703X X X X Extracts X X X X X X X X Extracts X X X X ..... #39;ble Tribunal was justified in holding that Working Capital adjustment can be made to the arms length operating margin of the comparables under Rule 10B (1)(e)(iii) of the Income Tax Rules, 1962? (2) Whether on the facts and in the circumstances of the case and in law the Tribunal was justified in holding that adjustment on account of higher import cost to the arms length operating margin of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... HARMADHIKARI AND A.K. MENON, JJ. For the Appellant : Mr. Vimal Gupta, Sr. Advocate with Mr.Vipul Arun Bajpayee For the Respondent : Mr. P.J. Pardiwalla, Sr. Advocate with Mr.Nishant Thakker and Ms.Megna Bansal i/b PDS Legal ORDER P.C.: 1. After having heard both the sides we proceed to admit the appeal as it involves substantial questions of law. It is admitted on the reframed questions ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e involved even though the same is contrary to the proviso to Section 92C(2) as amended with effect from 1.10.2009? (4) Whether on the facts and in the circumstances of the case and in law the Hon'ble Tribunal was justified in holding that Transfer Pricing adjustment is to be made only with reference to sales related to the import of components and spares procured from Associated Enterprises ..... X X X X Extracts X X X X X X X X Extracts X X X X
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