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2017 (12) TMI 631 - HC - Income TaxTPA - Computation of income from international transaction having regard to arm's length price - comparability selection of M/s.HMT Limited - Held that:- In the instant case, whether M/s.HMT Limited can be a comparable or not is a factual issue. The learned Tribunal has factually assessed the similarities between M/s.HMT Limited and the respondent assessee and the same, in our considered opinion, does not warrant interference of this Court under Section 260A of the Income Tax Act, 1961.
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