Court Rules Transfer Pricing Comparables Issues Often Lack Substantial Legal Questions in Arm's Length Price Cases.
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....TPA - comparable selection - substantial question of law - the Revenue has routinely brought such matters before this Court knowing fully well that the Transfer Pricing particularly with regard to exclusion and inclusion of certain comparables to determine Arm's Length Price (ALP) would not necessarily give rise to purely legal questions or substantial questions of law.....
TaxTMI