Supreme Court · 2023 INSC 394 · Decided 19 April 2023
Sap Labs India Private Limited v. Income Tax Officer, Circle 6, Bangalore
- Court
- Supreme Court of India
- Citation
- 2023 INSC 394 · [2023] 4 S.C.R. 430
- Case number
- CIVIL APPEAL No. 8463/2022
- Decided
- 19 April 2023
- Bench
- M.R. SHAH, M.M. SUNDRESH (2-judge bench)
- Outcome
- Appeal(s) allowed
- Case type
- Civil
- Acts & sections cited
- Income Tax Act Section 92, 92Ato92CA, 92D, 92E, 92F, 260
Headnote
Income Tax Act, 1961 : ss. 92, 92A to 92CA, 92D, 92E, 92F and 260 A - Transfer pricing matters - Arm length price, determination of - Arm length price, determined by the tribunal - Thereafter, determination of the arm's length price by the of powers u/s. 260A - Permissibility of - Held: There cannot be any absolute proposition of law that in all cases where the tribunal has determined the arm's length price the same is final and cannot be the subject matter of scrutiny by the High Court in an appeal u/s 260A -
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