PR. COMMISSIONER OF INCOME TAX v. M/S ISG NOVASOFT TECHNOLOGIES LTD.
Supreme Court of India | Diary 10104/2019
Status
Judgement - of Main Case
Decided On
19-04-2023
Bench
HON'BLE MR. JUSTICE UDAY UMESH LALIT, HON'BLE MS. JUSTICE INDIRA BANERJEE and HON'BLE MR. JUSTICE M.R. SHAH
Petitioner
PR. COMMISSIONER OF INCOME TAX
Respondent
M/S ISG NOVASOFT TECHNOLOGIES LTD.
Primary Holding
**Primary Holding:** Determination of arm's length price in transfer pricing matters is not purely a question of fact immune from appellate scrutiny; a substantial question of law under Section 260A of the Income Tax Act, 1961 arises where the Tribunal's determination is contrary to the prescribed statutory guidelines under Chapter X and Rules 10A–10E, even absent a plea of perversity.
Full judgment text is temporarily unavailable. Please try again later.
You can download the PDF instead.