High Court Finds Exports to Foreign Associate Not Comparable with Goods Sold in Domestic Market

This case note reviews the High Court decision in Principal Commissioner of Income-tax-5, Pune v. Keihin Fie (P.) Ltd, which held that margins derived on the export of components and parts to an associated enterprise of the taxpayer were not comparable with the margins derived from sales of goods made in the domestic market because the parts and finished goods were not comparable and the classes of customers to which they were sold were different.