https://www.taxtmi.com/caselaws?id=363174 The High Court dismissed the appeal by the Appellants-Revenue, finding no substantial question of law. The Tribunal's exclusion of specific companies from comparables for Transfer Pricing adjustments was upheld, emphasizing functional comparability. The ALP determination for deductions under Section 10A of the Income Tax Act followed precedents, excluding specific expenses from turnover calculations. The judgment stressed the importance of a consistent approach in interpreting tax provisions. The decision clarified Transfer Pricing methods and deductions under the Act, requiring clear perversity for appeals under Section 260-A. en-us Fri, 29 Jun 2018 00:00:00 +0530 Tue, 30 Jul 2019 16:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=363174 The High Court dismissed the appeal by the Appellants-Revenue, finding no substantial question of law. The Tribunal's exclusion of specific companies from comparables for Transfer Pricing adjustments was upheld, emphasizing functional comparability. The ALP determination for deductions under Section 10A of the Income Tax Act followed precedents, excluding specific expenses from turnover calculations. The judgment stressed the importance of a consistent approach in interpreting tax provisions. The decision clarified Transfer Pricing methods and deductions under the Act, requiring clear perversity for appeals under Section 260-A. Case-Laws Income Tax Fri, 29 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=363174