Ita/931/2018 Of The Pr. Commissiqner Of Income Tax-3 v. Frigoglass India Pvt. Ltd

$~38 * IN THE HIGH COURT OF DELHI AT NEW DELHI+ ITA 931/2018 THE PR. COMMISSIQNER OF INCOME TAX-3,..... Appellant Through: Mr. Ruchir Bhatia, Advocate versus FRIGOGLASS INDIA PVT. LTD ..... Respondent Through: CORAM:HON'BLE MR. JUSTICE SANJIV KHANNA HON'BLE MR. JUSTICE CHANDER SHEKHAR O R D E R % 28.08.2018 This appeal by the Revenue under Section 260A of the income Tax Act, 1961 in the case of Frigoglass India Pvt. Ltd. relates to assessment year 2013-2014 and arises from the order of the Income Tax Appellate Tribunal dated 9[th] February, 2018 in ITA No.7116/Del/2017. The issue raised in the present appeal relates to segregation of royalty as a separate and independent international transaction and its benchmarking. Similar issue was raised by the Revenue in the case of the respondent-assessee in ITA No.123/2017 for the assessment year 2011-12.The appeal preferred by the Revenue was dismissed vide order dated 3[rd] March, 2017. As the issue raised has already been decided, no substantial question of law arises for consideration. Appeal is dismissed in limine, without any order as to costs. SANJIV KHANNA, J AUGUST 28, 2018/tp/na CHANDER SHEKHAR, J