https://www.taxtmi.com/caselaws?id=434603 The High Court upheld the ITAT's decision to exclude three companies, namely Certification Engineering International Ltd., HSCC India Ltd., and Mitcon Consultancy & Engineering Services Ltd., from the list of comparables for determining the Arm's Length Price in international transactions. The Court agreed with the ITAT's detailed analysis, finding functional dissimilarities between the excluded companies and the assessee. The judgment emphasized the significance of functional similarity in selecting comparables and affirmed that no substantial question of law warranted consideration, reinforcing the importance of consistent decisions in transfer pricing determinations. en-us Wed, 09 Nov 2022 00:00:00 +0530 Mon, 27 Feb 2023 14:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434603 The High Court upheld the ITAT's decision to exclude three companies, namely Certification Engineering International Ltd., HSCC India Ltd., and Mitcon Consultancy & Engineering Services Ltd., from the list of comparables for determining the Arm's Length Price in international transactions. The Court agreed with the ITAT's detailed analysis, finding functional dissimilarities between the excluded companies and the assessee. The judgment emphasized the significance of functional similarity in selecting comparables and affirmed that no substantial question of law warranted consideration, reinforcing the importance of consistent decisions in transfer pricing determinations. Case-Laws Income Tax Wed, 09 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434603