2017 (9) TMI 1676 - HC - Income Tax

Exclusion of comparables on the grounds of functional dissimilarity - method for comparables analysis was the Transaction Net Margin Method - Held that - Having perused the impugned order of the ITAT 2017 (8) TMI 225 - ITAT DELHI the Court is of the view that no substantial question of law arises therefrom in the facts and circumstances of the case. The question of law is left open to be urged in an appropriate case.

Summary

The Delhi High Court dismissed the Revenue's appeal under Section 260A of the Income Tax Act, 1961 against the ITAT's order dated 3rd January, 2017 for the AY 2010-11. The appeal concerned the exclusion of comparables based on functional dissimilarity in the Transaction Net Margin Method analysis. The Court found no substantial question of law in the case.