Shanti Prime Publication Pvt. Ltd.
Section 92C of the Income Tax Act, 1961 — Transfer Pricing — Computation of arms length price — Revenue is regularly filing appeals from the orders of The Tribunal in respect of transfer pricing particularly with regard to exclusion and inclusion of certain companies as comparables which results in the orders of the tribunal which are essentially findings of facts in respect of inclusion and exclusion of a comparable been challenged without pointing out in any manner perversity of finding or failure to adhere to the settled principles of law while determining comparables such as rule 10 B which unnecessarily takes up the scarce time of the court, thus, revenue and the assessee in general are urged to review such appeal filed by them and withdraw the same — Principal Commissioner of Income tax vs. Barclays Technology Centre India P. Ltd. [2018] 305 CTR (Bombay) 193