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2018 (7) TMI 2101 - HC - Income TaxTPA - comparable selection - ALP - substantial question of law or fact - HELD THAT:- As decided in Pri. Commissioner of Income Tax & Anr. V/ s. M/s.Softbrands India Pvt. Ltd. [2018 (6) TMI 1327 - KARNATAKA HIGH COURT] wherein it has been observed that unless the finding of the Tribunal is found ex facie perverse, the Appeal u/ s. 260-A of the Act, is not maintainable. We make it clear that the same yardsticks and parameters will have to be applied, even if such appeals are filed by the Assessees, because, there may be cases where the TFbunal giving its own reasons and findings has found certain comparables to be good comparables to arrive at an 'Arm's Length Price' in the case of the assessees with ' which the assessees may not be satisfied and have filed such appeals before this Court. Therefore we clarify that mere dissatisfaction with the findings of facts arrived at by the learned Tribunal is not at all a sufficient reason to invoke Section 260-A of the Act before this Court - We are of the considered opinion that no substantial question of law arises for consideration in the present case.
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