IT : Where Tribunal had given cogent reasons and detailed findings on application of filters and selection of comparables, such findings of Tribunal could not have been perverse in any manner so as to require interference under section 260-A. Had it been a case of substantial question of interpretation of provisions of Double Taxation Avoidance Treaties (DTAA), interpretation of provisions of the Income Tax Act or Overriding Effect of the Treaties over the Domestic Legislations or the questions
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