Entire exercise of making TP adjustments is a matter of estimate of a broad & fair guess-work

PCIT Vs Mount Kellett Capital Management India Pvt. Ltd. (Bombay High Court) Entire exercise of making transfer pricing adjustments on the basis of comparables is nothing but a matter of estimate of a broad and fair guess-work of the authorities based on factual relevant materials brought before the authorities, i.e., the TPO or Dispute Resolution Panel (DRP) or ITAT, which are the fact finding authorities. FULL TEXT OF THE JUDGMENT/ORDER of BOMBAY HIGH COURT 1. The following three substantial question of law has been proposed in this appeal. QUESTION OF LAW 1. Whether on the facts and circums...