https://www.taxtmi.com/highlights?id=95549 Transfer pricing adjustment based on selection of comparables was challenged on the ground that the excluded companies should have been retained. The court upheld exclusion because the fact-finding authority had concluded that the proposed comparables failed the functional similarity test, being engaged in activities other than the tested export service activity, and also failed the 75% export turnover filter since their export income was materially below the threshold while the tested party's revenue was entirely export-derived. As these determinations were pure findings of fact accepted by the appellate tribunal, no substantial question of law arose, and the appeal was dismissed. - HC en-us Tue, 30 Dec 2025 13:23:30 +0530 Tue, 30 Dec 2025 13:23:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=95549 Transfer pricing adjustment based on selection of comparables was challenged on the ground that the excluded companies should have been retained. The court upheld exclusion because the fact-finding authority had concluded that the proposed comparables failed the functional similarity test, being engaged in activities other than the tested export service activity, and also failed the 75% export turnover filter since their export income was materially below the threshold while the tested party's revenue was entirely export-derived. As these determinations were pure findings of fact accepted by the appellate tribunal, no substantial question of law arose, and the appeal was dismissed. - HC Highlights Income Tax Tue, 30 Dec 2025 13:23:30 +0530 https://www.taxtmi.com/highlights?id=95549