Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)
Transfer pricing study which was in good faith and with due diligence for 2 determining the arms' length price ('ALP') of the international transaction of sale of intangibles. 2.2 Not considering the valuation report issued by an independent valuer relied by the Appellant to evaluate the arm's-length nature of the said international transaction without giving any cogent reasons