CIT v. Keihin Fie ( P) Ltd ( 2018) 255 Taxman 191 ( Bom) (HC) Editorial: Keihin Fie ( P) Ltd v. ACIT ( 2015) 57 taxmann.com 287 ( Pune ) (Trib) is affirmed

S.92C: Transfer pricing – Comparable- While deterring ALP of components and parts exported to AE which are used in manufacturing of two wheelers cannot be compared with sale of finished goods in domestic market.

Dismissing the appeal of the revenue the Court held that ; while deterring ALP of components and parts exported  to AE which are used in  manufacturing of two wheelers cannot be compared with sale of finished goods in domestic market.( AY.2005 -06, to 2007 -08)