https://www.taxtmi.com/caselaws?id=415549 The High Court upheld the decisions of the ITAT in a transfer pricing dispute, emphasizing the importance of factual analysis and correct application of tests. The court found no substantial legal questions raised in the interpretation of Rule 10B(2) regarding the exclusion of comparable companies and determining functional comparability. The appellant's challenges regarding specific companies' exclusion were dismissed, with the court highlighting that transfer pricing adjustments are estimates based on relevant materials, and disagreements between the parties are common in selecting comparables. en-us Wed, 17 Nov 2021 00:00:00 +0530 Wed, 08 Dec 2021 08:57:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=415549 The High Court upheld the decisions of the ITAT in a transfer pricing dispute, emphasizing the importance of factual analysis and correct application of tests. The court found no substantial legal questions raised in the interpretation of Rule 10B(2) regarding the exclusion of comparable companies and determining functional comparability. The appellant's challenges regarding specific companies' exclusion were dismissed, with the court highlighting that transfer pricing adjustments are estimates based on relevant materials, and disagreements between the parties are common in selecting comparables. Case-Laws Income Tax Wed, 17 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=415549