https://www.taxtmi.com/caselaws?id=191816 The High Court of Delhi dismissed the appeal as no substantial questions of law arose from excluding comparables M/s Infosys Ltd. and M/s. Persistent Systems Ltd., and from the treatment of foreign exchange gain or loss in transfer pricing determination of ALP. The court's decision was based on the significant differences in activities and intangibles ownership, as well as the inappropriate reliance on a Safe Harbour Notification. en-us Fri, 07 Oct 2016 00:00:00 +0530 Tue, 25 Apr 2017 08:15:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=191816 The High Court of Delhi dismissed the appeal as no substantial questions of law arose from excluding comparables M/s Infosys Ltd. and M/s. Persistent Systems Ltd., and from the treatment of foreign exchange gain or loss in transfer pricing determination of ALP. The court's decision was based on the significant differences in activities and intangibles ownership, as well as the inappropriate reliance on a Safe Harbour Notification. Case-Laws Income Tax Fri, 07 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=191816