2017 (9) TMI 1693

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..... y the Revenue nor in the grounds in the memorandum of Appeal is there a specific plea that the conclusions of the ITAT are perverse. In any event, the ground of perversity is not to be casually urged. It has to be supported by a proper pleading which again has to be on the basis of a detailed study of the impugned order of the ITAT pointing out to the High Court in what manner the ITAT’s conclusio .....

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..... 016 passed by the Income Tax Appellate Tribunal ( ITAT ) in ITA No.1195/Del/2014 for the Assessment Year 2006-07. 2. The question of law urged by the Revenue pertains to inclusion and exclusion of comparables for determining the arms length price (ALP) for the purpose of transfer pricing adjustment arising out of the international transactions entered into by the Assessee with its Associated En .....

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..... pleading which again has to be on the basis of a detailed study of the impugned order of the ITAT pointing out to the High Court in what manner the ITAT s conclusions can be said to be perverse. This condition is not met in the present case. Incidentally, even the word perversity has not been used anywhere in the questions of law or in the grounds urged before the Court. 5. The exclusion and .....

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