2017 (9) TMI 1693

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....This is an appeal by the Revenue against the order dated 13th December, 2016 passed by the Income Tax Appellate Tribunal ('ITAT') in ITA No.1195/Del/2014 for the Assessment Year 2006-07. 2. The question of law urged by the Revenue pertains to inclusion and exclusion of comparables for determining the arms length price (ALP) for the purpose of transfer pricing adjustment arising out of the interna....

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....y is not to be casually urged. It has to be supported by a proper pleading which again has to be on the basis of a detailed study of the impugned order of the ITAT pointing out to the High Court in what manner the ITAT's conclusions can be said to be perverse. This condition is not met in the present case. Incidentally, even the word 'perversity' has not been used anywhere in the questions of law ....