https://www.taxtmi.com/caselaws?id=444338 The Court set aside the Tribunal's decision to exclude Onward Technologies Limited (OTL) as a comparable in a transfer pricing dispute, finding the exclusion based on incorrect facts and without proper discussion on the Tribunal's powers under Section 254. The Court directed the Tribunal to reconsider the issue, focusing on the scope of its powers before determining OTL's validity as a comparable. The decision favored the appellant/assessee, and the appeal was disposed of with instructions for the Tribunal to reassess the matter in line with the Court's guidance on Section 254 of the Income Tax Act, 1961. en-us Fri, 01 Sep 2023 00:00:00 +0530 Fri, 13 Oct 2023 09:01:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444338 The Court set aside the Tribunal's decision to exclude Onward Technologies Limited (OTL) as a comparable in a transfer pricing dispute, finding the exclusion based on incorrect facts and without proper discussion on the Tribunal's powers under Section 254. The Court directed the Tribunal to reconsider the issue, focusing on the scope of its powers before determining OTL's validity as a comparable. The decision favored the appellant/assessee, and the appeal was disposed of with instructions for the Tribunal to reassess the matter in line with the Court's guidance on Section 254 of the Income Tax Act, 1961. Case-Laws Income Tax Fri, 01 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444338