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The HC affirmed the appellate authority's determination that the assessee's challenge to inclusion of two comparables was unsustainable where the comparables failed the prescribed 75% segment-revenue filter. The court held that, although segment-level financials may establish ALP where authentic and available, it is impermissible to circumvent an explicit selection filter by extracting segment figures when the comparable's relevant segment constitutes less than 75% of total revenue. Consequently the CIT(A)'s exclusion of those comparables stood unassailable and raised no substantial question of law. The assessment adjustment based on the remaining comparable set was thus upheld.
The HC affirmed the appellate authority's determination that the assessee's challenge to inclusion of two comparables was unsustainable where the comparables failed the prescribed 75% segment-revenue filter. The court held that, although segment-level financials may establish ALP where authentic and available, it is impermissible to circumvent an explicit selection filter by extracting segment figures when the comparable's relevant segment constitutes less than 75% of total revenue. Consequently the CIT(A)'s exclusion of those comparables stood unassailable and raised no substantial question of law. The assessment adjustment based on the remaining comparable set was thus upheld.
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