CIT vs PHILIP MORRIS SERVICES INDIA SA
Whether the Tribunal erred in directing exclusion of five companies (Apitco Ltd., Cameo Corporate Services, Global Procurement Consultants Ltd., Killik Agencies and Marketing Ltd., and TSR Darashaw Ltd.) from the list of comparables for benchmarking the arm's length price of international transactions relating to market support services --- Held No, as the Tribunal's findings were factual and disclosed functional dissimilarities, raising no substantial question of law.
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