Dismissing the appeal of the revenue the Court held that order of Tribunal upholding exclusion of ten comparables for purpose of determination of arm’s length price of international transactions involving is question of fact and does not involve any substantial question of law. (AY. 2008-09)
PCIT v. Evaluserve.Com (P) Ltd. (2021) 124 taxmann.com 210 (Delhi)(HC) Editorial: SLP of revenue is dismissed, as there was delay of 359 days in filing said petition and explanation offered in support of prayer for condonation was not satisfactory, PCIT v. Evaluserve.Com (P) Ltd. (2021) 277 Taxman 392 (SC)
S. 92C : Transfer pricing-Arm’s length price-Exclusion of ten comparables-Finding of fact-No substantial question of law. [S. 260A]