Dismissing the appeal of the revenue the Court held that ; The categorical finding of fact by the ITAT that a comparable (Motilal Oswal) is engaged in a qualitatively different and diversified business than that of the assessee cannot be challenged as a substantial question of law as the finding is not perverse or vitiated by any error apparent on the face of the record.( ITA No. 406 of 2016, dt. 18.09.2018) ( AY. 2010-11)
PCIT v. NVP Venture Capital India Pvt. Ltd ( 2018) 170 DTR 417/305 CTR 200/ (2019) 412 ITR 335 (Bom)(HC) www.iatonline.org.
S. 92C : Transfer pricing – Comparable – The categorical finding of fact by the ITAT that a comparable (Motilal Oswal) is engaged in a qualitatively different and diversified business than that of the assessee cannot be challenged as a substantial question of law as the finding is not perverse or vitiated by any error apparent on the face of the record.[ S 92CA,.260A ]