PCIT v. Eight Roads Investment Advisors Pvt. Ltd. (2020) 424 ITR 563/ 189 DTR 123/ 313 CTR 365/ 274 Taxman 71 (Bom)(HC)

S. 92C : Transfer pricing – Arm’s length price – Comparable -Question of fact – No substantial question of law. [ S92CA 260A ]

Dismissing the appeal of the revenue the Court held that the Tribunal had considered the case of each comparable company and discussed the parameters of the comparables for the purposes of including or excluding them as comparables on the basis of the functionality of the companies in the public domain. Such a detailed exercise having been undertaken by the Tribunal qua each and every comparable company, the reasons given by the Tribunal could not be faulted in respect of the comparable companies. The findings arrived at by the Tribunal were entirely findings of fact and the Revenue had failed to show any perversity in the order. The order of the Tribunal was valid and no question of law arose from it.( AY.2010-11)