Karnataka HC backs Huawei transfer-pricing exclusion, RPT filter
In short
The Karnataka High Court dismissed the Revenue’s appeal against Huawei Technologies. It upheld excluding comparables that were functionally different and kept the 15% related-party-transaction filter under Section 260A of the Income Tax Act, 1961.
This matters for transfer-pricing disputes and for Huawei Technologies. The reporting does not state the tax amount, the assessment year, or any further outcome.
What the reporting says
The Karnataka High Court dismissed the Revenue's appeal against Huawei Technologies and upheld exclusion of functionally different comparables plus a 15% related-party-transaction filter under Section 260A of the Income Tax Act, 1961. The available reporting says the court found no substantial question of law on those transfer-pricing issues. The exact tax effect, underlying assessment year, and any monetary adjustment are not stated in the available reporting.
Why it matters
The Karnataka High Court ruled against the Revenue in a transfer-pricing dispute involving Huawei Technologies, according to the available reporting. It upheld the exclusion of functionally different comparables and the use of a 15% related-party-transaction filter, saying these issues did not raise a substantial question of law under Section 260A of the Income Tax Act, 1961. The reporting does not state the tax impact or any adjustment amount.