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Whether on the facts and in the circumstances of the case, the Tribunal is right in applying first and second proviso of Section 92C of the Act and allowing +1-5% range in the case where there is only one reference rate of RBI as a benchmarking rate for determining Arms' Length Price and Tribunal cannot go into issue as to how RBI decides a reference rate of price of a currency which was not an issue before Tribunal?

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Section 92C of the Income-tax Act, 1961 —Transfer pricing—Present tenor as to whether the comparables have been rightly picked up or not, filters for arriving at the correct list of comparables have been rightly applied or not, do not give rise to any substantial question of law, therefore, present appeals filed by the Revenue do not give rise to any substantial question of law and the suggested substantial questions of law do not meet the requirements of Section 260A - PR. CIT V/s UAE EXCHANGE AND FINANCIAL SERVICE LTD. - [2018] 2 ITCD Online 111 (KARN)

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