2019 (7) TMI 1591 - HC - Income Tax

TP Adjustment - Comparable selection - HELD THAT - Revenue concerns the exclusion of four comparables by the ITAT and inclusion of one as suggested by the Assessee. The Court notes that the ITAT has given detailed reasons in support of its conclusions by discussing each of the comparables from the point of view of the functionality assets and risk test in terms of Rule 10B of the Income Tax Rules. Court is unable to find any legal infirmity in the impugned order which gives rise to any the substantial question of law that requires determination. The appeal is accordingly dismissed.

Summary

The High Court dismissed the Revenue's appeal against an ITAT order regarding the exclusion of four comparables and inclusion of one for Assessment Year 2011-2012. ITAT provided detailed reasons for its conclusions based on Rule 10B of the Income Tax Rules. No legal infirmity found in the impugned order. The appeal was dismissed.