Inclusion or exclusion of comparables per se cannot be treated as a question of law

PCIT Vs Macquarie Global Services Pvt. Ltd. (Delhi High Court) HC held held that inclusion or exclusion of comparables per se cannot be treated as a question  of law unless it is demonstrated to the Court that the Tribunal took into account irrelevant consideration or excluded irrelevant factors in the ALP that impact significantly. In our view, the ITAT has not committed any perversity or applied incorrect principle to the given facts and therefore, we do not find that any substantial questions of law arise for consideration in the present appeal. Accordingly, the same is dismissed. FULL TEX...