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| The Tax Publishers2020 TaxPub(DT) 4554 (Karn-HC) INCOME TAX ACT, 1961
Section 92C
Since issue with regard to functional similarity of the assessee was examined in detail by Tribunal, therefore, substantial question of law framed by a bench of this court in fact, did not arise for consideration.
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Transfer pricing - Computation of arm's length price - Selection of comparables -
Issue arose for consideration as to whether Tribunal was right in law in excluding Celestial Labs Ltd., Infosys Technologies Ltd, KALS Information Systems Ltd., Tata Elxsi Ltd. Wipro Ltd and Lucid Software Ltd., by placing reliance on its own order without appreciating the functional similarity of the assessee company with the above comparables and without going into merits of each of the case. Held: On perusal of submissions made by parties and on carefully going through the order passed by the Tribunal, it was evident that issue with regard to functional similarity of assessee was examined in detail by Tribunal, therefore, substantial question of law framed by a Bench of this court, in fact, did not arise for consideration.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2008-09
INCOME TAX ACT, 1961
Section 92C
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