https://www.taxtmi.com/caselaws?id=468259 Transfer pricing comparability findings based on functional dissimilarity are factual determinations and ordinarily do not raise a substantial question of law under section 260-A unless shown to be ex facie perverse; exclusion of companies from the comparable set was therefore not interfered with. Employees' provident fund and ESI contributions deposited by the return-filing due date were treated as deductible, because the relevant expression "contribution" was applied to both employer and employee contributions. The appeal was dismissed, with no substantial question of law arising on the transfer pricing ground and the deduction issue resolved in favour of the assessee. en-us Thu, 05 Jul 2018 00:00:00 +0530 Fri, 24 Apr 2026 18:33:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468259 Transfer pricing comparability findings based on functional dissimilarity are factual determinations and ordinarily do not raise a substantial question of law under section 260-A unless shown to be ex facie perverse; exclusion of companies from the comparable set was therefore not interfered with. Employees' provident fund and ESI contributions deposited by the return-filing due date were treated as deductible, because the relevant expression "contribution" was applied to both employer and employee contributions. The appeal was dismissed, with no substantial question of law arising on the transfer pricing ground and the deduction issue resolved in favour of the assessee. Case-Laws Income Tax Thu, 05 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468259