Home Case Index All Cases Income Tax Income Tax + SCH Income Tax - 2023 (5) TMI SCH This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2023 (5) TMI 486 - SCH - Income TaxTP Adjustment - comparable selection - ITAT excluding M/s Eclerx Services Pvt. Ltd, TCS E-Serve Ltd, BNR Udyog Ltd. and Excel Infoways Ltd as comparables for determining arm’s length price - High Court has observed that perusal of the impugned order reveals that the ITAT has given cogent reasons for excluding the aforesaid four companies as comparables. HELD THAT: - In view of the matter and in the peculiar facts and circumstances of the case, we see no reason to interfere with the impugned judgment and order passed by the High Court. The Special Leave Petition stands dismissed. However, the question of law on the powers of the High Court to consider the findings recorded by the Transfer Pricing Officer and/or the ITAT are kept open. The present Special Leave Petition is considered on the peculiar facts of the case and the question of law on the aforesaid is kept open.
|