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TMI Blog2025 (3) TMI 308X X X X Extracts X X X X X X X X Extracts X X X X ..... onal transactions where the assessee has selected TNMM and applied the same on entity level - HELD THAT:- Although it is correct that Income Tax Appeal [2024 (9) TMI 1703 - BOMBAY HIGH COURT] we cannot overlook the fact that at that time, the decisions in Spicer India Ltd. [2023 (7) TMI 139 - BOMBAY HIGH COURT] and Hindustan Unilever Ltd. [2016 (7) TMI 1245 - BOMBAY HIGH COURT] had not been delive ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Thakkar a/w. Ms. Jasmin Amaalsadvala a/w. Mr. Bhavesh Bhatia I/b. Lumiere Law Partners,. PC:- 1. Heard learned counsel for the parties. 2. This appeal concerns the assessment year 2009-10. 3. Mr Khanchandani, learned counsel for the appellant (Revenue), presses for admission of this appeal only on the following substantial question of law. "Whether on the facts and circumstances of the cas ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... such appeal was admitted on 25 September, 2014. He pointed out that the fourth substantial question of law admitted by order dated 25 September 2014 is the substantial question of law now proposed by the appellant(revenue) in this appeal. Accordingly, he submitted that this appeal may be admitted on the above substantial question of law. 5. Mr. Thakkar, learned counsel for the respondent (assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 7. Although it is correct that Income Tax Appeal No. 871 of 2012 was admitted by this Court on 25 September 2014, we cannot overlook the fact that at that time, the decisions in Spicer India Ltd.(supra.) and Hindustan Unilever Ltd. (supra.) had not been delivered. The decisions of the Coordinate Bench hold that benchmarking should be done only on associated enterprise or related party transactions ..... X X X X Extracts X X X X X X X X Extracts X X X X
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