Dismissing the appeal of the revenue the Court held that , Unless it is shown that there are important functional dissimilarities or other material facts ,exclusion or inclusion of other comparable would not constitute substantial question of law .
CIT v. Becton Dickinson India (P) Ltd ( 2018) 92 taxmann.com 45/254 Taxman 382 ( Delhi) (HC)
S. 92C : Transfer pricing – Arm’s length price -Unless it is shown that there are important functional dissimilarities or other material facts ,exclusion or inclusion of other comparable would not constitute substantial question of law [ S.260A ]