Supreme Court of India

Sap Labs India Private Limited v. Income Tax Officer, Circle 6, Bangalore

Neutral citation
Reported as [2023] 4 S.C.R. 430
Bench M. R. Shah and M. M. Sundresh JJ.
Decided 19 April 2023

INSC stands for INDIAN SUPREME COURT. A neutral citation scheme assigned by the Court itself, so a judgment can be cited without depending on a commercial law reporter. INSC is the neutral citation scheme assigned by the Supreme Court, so a judgment can be cited without depending on a commercial law reporter.

What the Court ordered

In view of the above and for the reasons stated above , all these appeals are allowed.

Judgment, page 14

From the headnote

Income Tax Act, 1961 : ss. 92, 92A to 92CA, 92D, 92E, 92F and 260 – Transfer pricing matters – Arm length p rice, determination of – Arm length price, determined by the tribunal – Thereafter, determination of the arm’s length price by the High Court, in exercise 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 – When the determination of the arm’ s length price is

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