HC on filing of Transfer Pricing Appeals in ritualistic manner

Pr. CIT Vs Barclays Technology Centre India  Private Ltd. (Bombay High Court) HC recorded the fact that Revenue  is regularly  filing appeals  from the orders of the Tribunal in respect of Transfer Pricing particularly with regard to exclusion and inclusion of certain companies as comparables to determine ALP of tested parties. These appeals are being filed in a ritualistic manner. This results in the orders of the Tribunal which are essentially findings of fact in respect of  exclusion/ inclusion  of a comparable being challenged without pointing out in any manner perversity of ...