PCIT v. Bechtel India Pvt. Ltd. (2023) 451 ITR 208 / 330 CTR 400 (Delhi)(HC) Editorial: Order in Bechtel India Pvt. Ltd. v. Add CIT (2021) 86 ITR 544 (Delhi)(Trib), affirmed.

S. 260A : Appeal-High Court-International transactions-Arm’s length price-Comparable-Question of fact. [S. 92C]

Dismissing the appeal of the Revenue the Court held that findings of facts arrived at by the Tribunal are final and are binding on the court. The High Court cannot disturb findings of fact 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.2013-14)