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2017 (9) TMI 1693 - DELHI HIGH COURTInclusion and exclusion of comparables for determining the arms length price (ALP) for the purpose of transfer pricing adjustment - as submitted that the conclusions of the ITAT in respect of each of the comparables are perverse - Held that:- Neither in the questions of law as urged by the Revenue nor in the grounds in the memorandum of Appeal is there a specific plea that the conclusions of the ITAT are perverse. In any event, the ground of perversity 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. The exclusion and inclusion of comparables is by and large an exercise of analysis of facts. If there has to be a substantial question of law framed on such an issue, the Revenue should come up with a proper plea based on a detailed study of the impugned order of the ITAT. This Court is therefore not persuaded in the present case to hold that any substantial question of law has arisen for consideration from the impugned order of the ITAT.
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