2009 (2) TMI 832

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....substantial questions of law: 34. Whether the Tribunal was correct in holding that the transfer pricing provisions cannot be invoked and applied in the case where the provisions of section 10A of the Act, is availed of by the assessee, particularly when the language of the statute is plain and unambiguous? 36. Whether the Tribunal was correct in holding that the taxpayer was just....

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....justment on account of capital and risk, which was contrary to Rule 10B(3)(ii) which provides for only reasonably accurate adjustment? 39. Whether the Tribunal was correct in holding that the companies with even a single rupee worth related party transactions should not be selected as a comparable and still proceeded to accept the taxpayer's comparable which had significant related pa....