CIT v. Gxs India Technology Centre Pvt. Ltd. (2019) 415 ITR 354 (Karn.) (HC)

S. 92C : Transfer pricing–Arm’s length price–Comparable–No question of law. [S. 260A]

Dismissing the appeal of the revenue the Court held that, the determination of the arm’s length price in an international transaction is a finding of fact. Whether the comparables have been rightly picked up or not, or filters for arriving at the correct list of comparables have been rightly applied or not, do not give rise to any substantial question of law. (AY. 2008 -09)