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2023 (8) TMI 679 - DELHI HIGH COURTTP Adjustment - comparable selection - HELD THAT:- For Accentia Technology Ltd. Tribunal notes that it has developed its own software, it is in the business of medical transcription services and not the BPO services and during the period in issue, it experienced an extraordinary economic event i.e., it had acquired 96% stake in Oak Technologies Inc. which added heft to both its top and bottom line. For Cosmic Global Ltd, the Tribunal has returned a finding of fact that it operated on a business model which was different from that of the respondent/assessee. According to the Tribunal, Cosmic Global Ltd outsourced a major part of its business and that in the relevant period, it had registered abnormal profit. According to us, these are findings of fact which cannot be termed as perverse. Even otherwise, we find that there is no question of law proposed by the appellant/revenue categorizing these findings as perverse. We are not inclined to interfere with the impugned order. According to us, no substantial question of law arises for our consideration.
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