Shanti Prime Publication Pvt. Ltd.
Section 92C of the Income Tax Act, 1961 — Transfer Pricing — Question whether the Tribunal was justified in ignoring the comparable company on the ground that the assessee company is functionally not comparable and also that the said company was selected as a comparable by the assessee itself for the AY 2008-09 is a sustainable question of law — Pr Commissioner of Income tax vs. PTC Software India P Ltd [2018] 305 CTR (Bombay) 187