Dismissing the appeal of the revenue the Court held that; The High Court cannot disturb findings of fact under section 260A of the Act, unless such findings are ex facie perverse and unsustainable and exhibit a total non-application of mind by the Tribunal to the relevant facts of the case and evidence before the Tribunal. ( AY. 2010-11)
CIT v. Kirloskar Toyota Textile Machinery P. Ltd. (2019) 412 ITR 359 (Karn)(HC)
S.92C : Transfer pricing – Arm’s length price – Comparable – No question of law – Appeal is not maintainable .[ S.260A ]