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IT/ILT: SLP dismissed against High Court ruling that while determining ALP of international transactions, benchmarking has to be done only on AE transactions and not for entire turnover

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■■■[2018] 99 taxmann.com 135 (SC)
SUPREME COURT OF INDIA
Commissioner of Income-tax-I
v.
Hindustan Unilever Ltd.*
A.K. SIKRI
AND ASHOK BHUSHAN, JJ.
SPECIAL LEAVE TO APPEAL (C) NO. 22381 OF 2017†
OCTOBER  29, 2018

 

Section 92C of the Income-tax Act, 1961 – Transfer pricing – Computation of arm’s length price (Comparables and adjustments/Adjustments – General principals) – Assessment year 2006-07 – High Court by impugned order held that while determining ALP of international transactions, benchmarking has to be done only on AE transactions and not for entire turnover –
Whether Special Leave Petition against impugned order was to be dismissed – Held, yes [Para 3]
[In favour of assesse]

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