Dismissing the appeal of the revenue the Court held that ; Transfer pricing disputes with regard to exclusion and inclusion of comparables to determine Arm’s Length Price (ALP) would not necessarily give rise to substantial questions of law except if there is perversity of finding or failure to adhere to the settled principles of law while determining comparables. .( ITA No. 522 of 2016, dt. 24.09.2018)
[Click here to download PDF file]http://itatonline.org/archives/wp-content/uploads/TIBCO-Transfer-Pricing.pdf