Dismissing the appeal of the revenue the court held that finding of fact given by the Tribunal that, functional dissimilarities and distinction in services provided has to be excluded .( AY.2011-12 )
CIT v. B. C. Management Services Pvt. Ltd. (2018) 403 ITR 45 / 253 Taxman 128 /164 DTR 299 / 302 CTR 167 (Delhi) (HC)
S.92C: Transfer pricing Arm’s Length Price -Selection of comparables — Functional dissimilarities and distinction in services provided has to be excluded . [ S.92CA ]