https://www.taxtmi.com/caselaws?id=352362 The High Court upheld the Tribunal's decision to include M/s. HMT Limited as a comparable for determining the arm's length price (ALP). The Court emphasized that functional similarity, not just turnover, should be considered in such determinations. The Court also ruled that the issue was factual and did not raise a substantial question of law under Section 260A of the Income Tax Act, 1961. Therefore, the Revenue's appeal was dismissed. en-us Tue, 05 Dec 2017 00:00:00 +0530 Tue, 24 Jul 2018 18:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=352362 The High Court upheld the Tribunal's decision to include M/s. HMT Limited as a comparable for determining the arm's length price (ALP). The Court emphasized that functional similarity, not just turnover, should be considered in such determinations. The Court also ruled that the issue was factual and did not raise a substantial question of law under Section 260A of the Income Tax Act, 1961. Therefore, the Revenue's appeal was dismissed. Case-Laws Income Tax Tue, 05 Dec 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=352362