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2018 (10) TMI 873 - HC - Income TaxTPA - Comparable selection - Held that:- In a detailed order passed by this court, it has been held that there is a difference between services and business of comparable like Motilal Oswal Investment Advisors Pvt. Ltd. and the assessee. The Division Bench held that the activities of Motilal Oswal Investment Advisors Pvt. Ltd. were functionally incomparable to the activities of investment advisory services rendered by the assessee to its associate enterprise. Here as well, similar is the factual position. Once the factual findings rendered in the impugned order are based on the materials before the tribunal, then, it is not permissible for us to re-appraise and re-appreciate the same and arrive at a different conclusion. No perversity has been demonstrated in the view taken by the tribunal nor is it vitiated by an error of law apparent on the face of the record. Consequently, none of the questions proposed before us can be treated as substantial questions of law.
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