Dismissing the appeal of the revenue the Court held that whether comparable had been rightly picked up or not does not give raise to any substantial question of law and unless perversity of finding of fact established no substantial question of law arises for consideration. ( AY. 2007 -08 )
PCIT v. Mphasis Ltd (2021) 133 taxmann.com 274/( 2022) 446 ITR 361 (Karn.)(HC) Editorial : SLP of revenue is dismissed ; PCIT v. Mphasis Ltd (2022) 284 Taxman 458 (SC)
S. 92C : Transfer pricing-Arm’s length price-Adjustment of filters, etc-No substantial question of law. [S. 92CA, 260A]