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2018 (7) TMI 2076 - KARNATAKA HIGH COURTTP Adjustment - ALP determination - substantial question of law or fact - HELD THAT:- This Court in a recent judgment in Pr. Commissioner of Income Tax, Bangalore and Another Vs. M/s. Softbrands India P.Ltd. [2018 (6) TMI 1327 - KARNATAKA HIGH COURT] has held that in these type of cases, unless an ex-facie perversity in the findings of the learned Income Tax Appellate Tribunal is established by the appellant, the appeal at the instance of an assessee or the Revenue under Section 260-A of the Act is not maintainable
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