https://www.taxtmi.com/caselaws?id=257078 The High Court dismissed the appeal by the Revenue against an ITAT order concerning the determination of arm's length price for income tax purposes. The Court upheld the ITAT's decision to include M/s. Capital Trust Ltd. as a comparable in transfer pricing studies, emphasizing the importance of functional profiles over arbitrary criteria and noting the inconsistency in applying turnover filters. The Court ruled that the ITAT's order did not raise a substantial question of law, leading to the dismissal of the appeal and all pending applications. en-us Tue, 24 Feb 2015 00:00:00 +0530 Tue, 11 Aug 2015 12:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=257078 The High Court dismissed the appeal by the Revenue against an ITAT order concerning the determination of arm's length price for income tax purposes. The Court upheld the ITAT's decision to include M/s. Capital Trust Ltd. as a comparable in transfer pricing studies, emphasizing the importance of functional profiles over arbitrary criteria and noting the inconsistency in applying turnover filters. The Court ruled that the ITAT's order did not raise a substantial question of law, leading to the dismissal of the appeal and all pending applications. Case-Laws Income Tax Tue, 24 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=257078