Transfer pricing comparables exclusion upheld in line with settled precedent, with no substantial question of law arising.

Transfer pricing comparables for software service providers were challenged, with the exclusion of M/s Infosys Ltd., M/s E-Infochips Ltd., E-Zest Solutions Ltd. and EClerx Services Ltd. upheld because the issue had already been decided in a recent case on the same set of comparables. The HC found the Tribunal's order consistent with that settled position and saw no basis to interfere. No substantial question of law arose, so the appeal was dismissed and the assessee succeeded.

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Issues: Whether the exclusion of M/s Infosys Ltd., M/s E-Infochips Ltd., E-Zest Solutions Ltd. and EClerx Services Ltd. as comparables in the transfer pricing exercise called for interference in appeal.

Analysis: The issue had already been considered in a recent decision dealing with the same transfer pricing comparables, where the exclusion of those companies was held to be justified. The impugned order was found to be in conformity with that settled position, and no basis was found to disturb the findings of the Tribunal. No substantial question of law arose for consideration.

Conclusion: The appeal was dismissed and the assessee succeeded.

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