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2019 (7) TMI 1147 - HC - Income TaxTP adjustment - exclusion and inclusion of comparables for the purposes of determining the Arm’s Length Price (‘ALP’) of the international transactions involving the Assessee - HELD THAT:- Having perused the charts, the Court finds that in respect of each of the comparables, the ITAT has given detailed reasons why the comparables should be rejected either because of failing the filter or because of functional dissimilarity. In some instances, the earlier decisions concerning this very Assessee have been followed. The Court is not persuaded that on the issue of exclusion and inclusion of comparables, particularly when the decisions of this Court on the topic including those concerning this very Assessee for AY 2010-2011 have been followed by the ITAT, the impugned order of the ITAT gives rise to a substantial question of law.
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