COMMISSIONER OF INCOME TAX-6 Vs. MERCK LTD

JUDGEMENT

(1.) This Appeal under Section 260-A of the Income Tax Act, 1961(the Act), challenges the order dated 19th July, 2013 passed by the Income Tax Appellate Tribunal (the Tribunal). The impugned order dated 19th July, 2013 relates to the Assessment Year 2003-04.

(2.) Although numerous questions have been raised in the memo of appeal, Mr. Suresh Kumar, learned Counsel appearing for the Revenue urges only the following three questions of law for our consideration:

(3.) Re: Question (a):- The aforesaid question raises two issues with regard to Arms Length Price (ALP) in respect of import of pigment and import of technical knowhow/consultancy by the Respondent-Assessee from its Associated Enterprises (AE). We shall consider each of them separately.