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The special leave petition is dismissed on the ground of low tax effect. Question of law is left open.

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Sec. 92C of the Income-tax Act, 1961 - Transfer pricing - The ground raised in the appeal of the revenue was with regard to the transfer pricing adjustment on account of deletion of two com-parables. High Court dismissed the revenue’s appeal holding that “the first comparable excluded by ITAT's order was excluded on the basis that the company was functionally dissimilar and that the segmental data for the assessment year with regard to the comparable segment was not available. The second comparable directed to be excluded was on the ground that the concern provided high end online software solutions unlike the assessee, which provided internet based medical health related services. The real services, therefore, were entirely dissimilar”. Revenue filed SLP which came to be dismissed on account of low tax effect. - PR. CIT V/s INDUCTIS INDIA (P.) LTD. - [2020] 270 TAXMAN 001 (SC)

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