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2016 (1) TMI 1493 - DELHI HIGH COURTTP Adjustment - comparable selection - exclusion of M/s. Cosmic Global Ltd. (‘CGL’) as a comparable by the Assessee - HELD THAT:- A perusal of the impugned order of the ITAT reveals that the ITAT was conscious of this fact and proceeded to assess on merits whether the Assessee was justified in seeking the exclusion of CGL as a comparable. The ITAT has set out detailed reasons why the said plea of the Assessee was justified. Inter alia it was noticed that CGL’s functional profile did not match that of the Assessee and a substantial portion of its earnings was on account of translation charges whereas the Assessee was not in that line of business at all. This being a purely factual determination, the Court is not persuaded to hold that any substantial question of law arises from the impugned order of the ITAT.
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