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)
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.