Dismissing the appeal of the revenue the Court held that the Appellate Tribunal rightly rejected the comparable hence no question of law . Similarly deletion of expenses u/s 14A is also question of fact . Accordingly the order of Tribunal is affirmed .
CIT v. Visual Graphics Computing Services India Pvt Ltd (2020) 274 Taxman 481/ 195 DTR 397/ (2021) 318 CTR 586 ( Mad)(HC)
S. 92C : Transfer pricing – Arm’s length price – Comparables- Different financial years – Rejection of comparable- Question of fact – Exempted income – Disallowance of expenses – Question of fact [ S.260A ]