PCIT v. Barclays Technology Centre India Pvt. Ltd. (2018) 409 ITR 138/ 305 CTR 193 /171 DTR 58 (Bom.) (HC)

S. 92C : Transfer pricing-Arm’s length price-Transactional net margin method—Exclusion of functionally different comparable companies-Finding of fact-No substantial question of law. [S. 260A]

Dismissing the appeal of the revenue the Court held that; exclusion of functionally different comparable companies-Finding of fact and the Department had failed to show how the finding arrived at by the Tribunal was perverse in any manner or that the analysis done by the Tribunal while excluding the four companies from the list of comparables, was in any manner contrary to the settled position in law.( AY.2008 -09)